FAA Hazardous Federal Aviation Materials Program · FAA Office of Security and Hazardous Materials...

Janet McLaughlin

FAA Office of Security and Hazardous Materials

Federal AviationAdministrationFAA Hazardous

Materials Program

ASTM Distribution Packaging Symposium April 2008

ASTM Distribution Packaging Conference - FAA Hazardous Materials Program

2Federal AviationAdministration

April 2008

Will Cover…

• Shipper Inspections• Batteries• Leaking Air Packaging• Cylinder explosion• FAA Web sites



April 2008

FAA Shipper Inspections

• Routine Shippers– Identified from shipping papers obtained

from air carriers at airports

• Priority Shippers– Identified by evaluating FAA and DOT

records



April 2008

Using New DOT-Wide Shipper Database to Set Inspection Priorities

• Approx 1.9M records – 220K companies– HM Incidents (DOT Form 5800)– HM Registrations (49 CFR 106.107)– Inter-modal Penalties – Prior inspections– Exemptions– Dunn and Bradstreet “DUNS” numbers– Standard Industrial Codes (SIC)



April 2008

Automated Outreach NoticesSince January ‘05

• As a indirect result of increased security screening of baggage and cargo

• More discrepancy reports from air carriers under 175.31 than ever before

• Developed internal web-based system to prioritize reports in terms of risk: Suspected Hazardous Objects Encountered in Screening (SHOES)

• 97% of passenger hazmat violations result in warning letter generated by SHOES



April 2008

Battery Issues…



April 2008

Battery Background• Battery problems have been cited in:

– NTSB Recommendations– GAO/OIG Reports

• 90+ aviation-related fires/dangerous heat– 28 lithium related incidents

• Two FAA Tech Center Reports• UK Civil Aviation Authority Report• CPSC Recalls



April 2008

Three Published Studies

• FAA - June, 2004, Flammability Assessment of Bulk-Packed, Non-rechargeable Lithium primary Batteries in Transport Category Aircraft

• FAA – September, 2006, Flammability Assessment of Bulk-Packed Rechargeable Lithium Ion Batteries

• Civil Aviation Authority, United Kingdom July, 2003, Dealing With In-Flight Lithium Battery Fires In Portable Electronic Devices



April 2008

Some Report Conclusions see http://www.fire.tc.faa.gov/

• Li-metal primary battery “cargo” fire can not be suppressed by Halon (FAA)

• Li-ion rechargeable battery “cargo” fire can be suppressed by Halon (FAA)

• Passenger-related rechargeable li-ion battery-powered device fire can be suppressed using the fire fighting equipment available to the crew (UK CAA)



April 2008

Failures of Li and Li-Ion Batteries

• There are many different types of failures of Li-Ion cells used in notebooks, camera, cell phones, etc. batteries.– There are many ways for particles/impurities to get into a cell during

the manufacturing processes– Flaws in Li-Ion cells can cause deposits or dendrites of Li metal or

copper to form in the battery. These can grow with each cycle of charging until an internal short circuit is caused

– The cathode materials of batteries are hard and rough and can wear down the manufacturing tools and can cause metal particles to contaminate the cell

• There are no industry "clean" standards for the Li and Li-Ion battery manufacturing processes other than a manufacturer's own quality control. Manufacturers of faulty cells had ISO 9000-series QC certifications.



April 2008

Failures of Li and Li-Ion Batteries

• For detecting problem cells, the UN and UL tests pale in effectiveness compared to internal quality control tests…– The reason is that internal QC tests are run on every batch– It is easy for manufacturers to adjust to standardized tests like

the UN and UL tests (and do the bare minimum to pass those tests)

– The subtle design changes that are allowed in the UN tests are exactly the kind of changes that cause problems in cell manufacturing. A different tool, a different supplier, a different assembly technique are where the problems are introduced

• The electronics of a device can cause good batteries to catch fire…Lithium fires burn hotter than the melting point of aluminum!

• The least damaged cell in a battery fire is often the one that had the original failure…Because the thermal runaway starts with the remaining cells with stored energy that elevate in temperature causing an unstable state



April 2008

External FAA Initiatives

• Working with industry trade associations to develop and publicize awareness campaign to inform the public of risks in carriage, stowage, and charging of batteries.

• Promulgate Advanced Notice of Proposed Rulemaking (ANPRM) to address questions and seek public response to restrict carriage, use, and recharging of batteries.

• Charter an Aviation Rulemaking Committee (ARC) to evaluate and provide recommendations to FAA on effects of stowage and carriage of energy sources onboard all-cargo and “combi” airplanes. Should be initiated in Summer 2008.

• Facilitate a means for industry trade associations to provide and report such incidents which would allow FAA to track and collect data on the number and type of reported battery incidents.– A web portal could be established for anonymous reporting

(PED and battery related incidents, etc.)



April 2008

Potential Hazardous Exposure

• Increased risks with the use of Li and Li-Ion battery applications and growing technologies in PEDs.

• Previous energy sources such as nickel-metal hydride, nickel cadmium, alkaline, even lithium disulfide, are less hazardous in carriage and in use.

• There have been TOO many reported incidents of battery failures in flight…– Fortunately no one was seriously injured



April 2008

ICAO Changes

• A45 is being removed.• Requirements are all included in packing

instructions.• There are 6 packing instructions:

– Lithium metal batteries• Batteries• Batteries packed with equipment• Batteries contained in equipment

– Lithium ion batteries• Batteries• Batteries packed with equipment• Batteries contained in equipment



April 2008

Hazmat PackagingUnacceptable Leak Rates

• Review of DOT incident reports reveals many leaking combination packages in air transport

• Studies sponsored by FAA and PHMSA show that air pressure and vibration can loosen caps on inner receptacles of UN spec packagings

• 49 CFR 173.27 requires “capability” but doesn’t require a pressure test.



April 2008

Hazmat PackagingRulemaking to address leaking packages

• PHMSA and FAA are evaluating the need for an ANPRM to solicit industry feedback on how we should fix the problem of leaking combination packagings in air transport.

Advance Notice of Proposed

Rulemaking

49 CFR 173.27(c)

Advance Notice of Proposed

Rulemaking

49 CFR 173.27(c)



April 2008

Cylinder residue



April 2008



April 2008

The Incident

• Cylinder manufactured in October 2007• Filled on 19 November 2007• Carried by air 27 November 2007 • Occurred on 3 December 2007



April 2008

The issues…..Classification

• Substance classified as UN3161 Liquefied gas, flammable, n.o.s.

• Contained 99.995% ethyl chloride and 50ppm division 6.1 pg III

• Technical Instructions/UN may not preclude this classification

• Highlighted other issues e.g. forbidden substances may be permitted by addition of small quantities of other dangerous goods



April 2008

The issues…..Compatibility

• Packing Instruction 200 appears to intend a prohibition on pure ethyl chloride only, not mixtures containing it

• Packing Instruction 200 says only that aluminium alloy cylinders are “not authorized”, but what does this mean?

• Part 6 of the Technical Instructions requires compliance with ISO 11114-1, but…

• ISO 11114-1 only says that aluminium alloy is “not recommended” but can be used if assessed and authorised by a “competent person”

• Matheson Gas Data Book does not warn against use of aluminium alloy cylinders



April 2008

The issues…..Compatibility

• ISO 11114-1, for ethyl chloride, states “No reaction with any common materials when dry. In the presence of water, slight risk of corrosion”

• But for Methyl bromide “RISK OF VIOLENT REACTIONS WITH AA”

• What percentage of ethyl chloride in a mixture is safe in an aluminium alloy cylinder?



April 2008

Other issues…..

• 8 gases referred to in the ISO Standard where brass valves are not recommended, but no applicable restriction specified in the Technical Instructions;

• For an oxidizing substance in an aluminium alloy cylinder, 7 other standards apply



April 2008

FAA Websites• FAA.GOV

– FAA’s public web site– FAA Flight Plan– Office of Security and Hazardous Materials (ASH)

Business Plan• ASH.FAA.GOV

– Links directly to Security & Hazmat section of FAA web site

– Brochures– Advisory Bulletins– Contact info



April 2008

The ASH.faa.govweb page has DG bulletins, guidance material, and regulatory notices.



April 2008

MSU CDP Published Studies

1. Singh, Paul; Burgess, Gary; Singh Jagjit. “Package Performance Testing of Dangerous Goods in High Altitude Shipments” HAZMAT Packager & Shipper, Volume 13, Number 6, March/April 2003

2. Singh, Paul; Burgess, Gary; Singh, Jagjit. “Package Performance Testing of Dangerous Goods in High Altitude Shipments,” Packaging Technology and Science, 16: 119-130, 2003

3. Singh, Paul; Burgess, Gary; Singh, Jagjit. “A New Test Method and Pictorial Markings for Packages Containing Liquid Dangerous Goods in High Altitude Shipments,” Journal of Testing and Evaluation, ASTM, Vol. 32, No. 5, 2004

4. Singh, Paul; Singh, Jagjit. “Pictorial Markings and Labels for Safe Transport and Handling of Packaged Goods”. Packaging Technology and Science, 18: 133-140, 2005

5. Singh, S. P., Burgess, G., Singh, J.*, Lockhart, H. “High Altitude Testing and Evaluation of Liquid Pharmaceutical Glass and Plastic Bottles to Detect Leaks,” Journal of ASTM International, Vol. 4, No. 3



April 2008

Janet McLaughlinFederal Aviation AdministrationOffice of Hazardous Materials, ADG-1800 Independence Ave. SW, Rm. 315Washington, DC [email protected] Safe Travel URL –http://safetravel.dot.gov

Thank You!Thank You!

mailto:[email protected]

http://safetravel.dot.gov/

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