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AIR • THE VERY SPECIFIC ISSUES PERTAINING TO THE CARRIAGE OF DANGEROUS GOODS BY AIR MEAN THAT ICAO’S DANGEROUS GOODS PANEL MUST INTERPRET THE UN PROVISIONS

THE INTERNATIONAL CIVIL Aviation Organisation’s (ICAO) Dangerous Goods Panel (DGP) held its 27th session in Montréal, Canada from 16 to 20 September 2019, with the aim of making progress on the development of the amendments to the Technical Instructions for the Transport of Dangerous Goods (Tis) that will be in effect in 2021 and 2022, subject to adoption by the ICAO Council in November 2020.

The meeting was attended by representatives of 21 contracting states and six non-governmental organisations. It was chaired by Micheline Paquette (Canada) with Teun Muller (Netherlands) elected as vice-chair. Dr Katherine Rooney, chief of ICAO’s Cargo Safety Section, acted as usual as secretary.

Those involved in the transport of dangerous goods by air most often use the Dangerous Goods Regulations (DGR) published by the International Air Transport Association (IATA), but need to be aware that the legal provisions are set by ICAO; its DGP also attempts to maintain harmonisation, insofar as is possible, with the UN Model Regulations on the Transport of Dangerous Goods, which also feed into the other modal, national and regional rulebooks. Any amendments adopted by ICAO will, therefore, be reflected in the 2021 edition of IATA’s DGR.

DGP was faced by a lengthy agenda, agreed by the ICAO Air Navigation Commission (ANC); however, its work was made easier by the fact that working groups had met the week before to carry out a lot of the donkey work.

UN AMENDMENTS The Panel examined the decisions adopted by the UN Committee of Experts on the Transport of Dangerous Goods (TDG) and the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) at its ninth session in December 2018, which were included in the 21st revised edition of the UN Model Regulations.

While there is a constant effort to maintain harmonisation, the practicalities and risks involved in the transport of dangerous goods by air are such that ICAO often feels the need to vary from the UN provisions. For instance, while the Panel included references to intermediate bulk containers (IBCs) and portable tanks in the definition of selfaccelerating polymerisation temperature (SAPT), this was accompanied by a note to specify that they are not permitted for transport by air. This follows an earlier decision by the Panel that definitions should be included in the Tis even if the item being defined is not permitted for transport by air.

In a similar vein, while DGP updated the list of references to provisions for which the transport of excepted packages of radioactive material would apply, it left out reference to the packaging orientation arrow provisions in 5;3.2.12 b), as it saw no value in it for air transport, and reference to the documentation provisions for consignments required to be shipped under exclusive use in 5;4.1.5.7.1 i), as these consignments would never be transported by air.

The new provisions agreed by the UN experts to exempt battery-powered data loggers and other similar devices from the provisions of the regulations led to considerable discussion. That exception applies only to devices attached to or integrated into containers, overpacks and packagings, not to devices shipped as cargo, but ICAO remains concerned that such devices may still be hazardous to an aircraft. It was decided to refer the matter to the newly formed Safe Carriage of Goods Specific Working Group for its opinion, even though there are concerns that any delay may cause problems in multimodal transport.

In considering this matter, DGP identified two areas of concern: the hazards posed by the potential for devices to cause electromagnetic interference with aircraft systems; and the hazards posed by the lithium batteries themselves. It was pointed out that the lithium batteries included in the devices would be active during transport and may be attached to packages containing dangerous goods that, in the normal course of events, would need to be separated from fully regulated lithium batteries carried as cargo.

In general, it was felt that mention needed to be made to address the issue, especially as the use of data loggers is becoming more widespread. However, it was also felt that the conditions under which the exception is permitted should be more stringent than those in the UN text. It was eventually agreed to adopt a new 1;1.1.5.1 i): data loggers and cargo tracking devices with installed lithium batteries, attached to or placed in packages, overpacks or unit load devices are not subject to any provisions of these Instructions provided the following conditions are met:

ANY LITHIUM BATTERY ON AN AIRCRAFT HAS THE

POTENTIAL TO CAUSE AN INCIDENT

1) the data loggers and cargo tracking devices must be in use or intended for use during transport; 2) each cell or battery must meet the provisions of Part 2;9.3 a), e), f) (if applicable) and g); 3) for a lithium ion cell, the Watt-hour rating must not be more than 20 Wh; 4) for a lithium ion battery, the Watt-hour rating must not be more than 100 Wh; 5) for a lithium metal cell, the lithium content must not be more than 1 g; 6) for a lithium metal battery, the aggregate lithium content must not be more than 2 g; 7) the number of data loggers or cargo tracking devices in or on any package or overpack must be no more than the number required to track or to collect data for the specific consignment; 8) the data loggers or cargo tracking devices must be capable of withstanding the shocks and loadings normally encountered during transport; 9) the data loggers or cargo tracking devices must not be capable of generating a dangerous evolution of heat; and

10) the data loggers or cargo tracking devices must meet defined standards for electromagnetic radiation to ensure that the operation of the device does not interfere with aircraft systems.

Note - This exception does not apply where the data loggers or cargo tracking devices are offered for transport as a consignment in accordance with Packing Instruction 967 or 970.

The Panel also felt it would be useful to review the provisions for active devices in Packing Instructions 967 and 970 and to develop a more systematic, performancebased approach to developing future provisions.

Also on the topic of lithium batteries, the Panel was not entirely happy with Special Provision A154, which prohibits the transport by air of lithium batteries that have been identified as being damaged or defective, and which had been revised to align with the UN Model Regulations. It seemed sensible to focus on determining that batteries are not damaged or defective, rather than take the UN approach of assessing whether they are.

It was decided to add a new sentence at the beginning of A154:

Lithium ion cells or batteries and lithium metal cells or batteries, identified as being defective for safety reasons, that have the potential of producing a dangerous evolution of heat, fire or short circuit are forbidden for transport (e.g. those being returned to the manufacturer for safety reasons or cells or batteries that cannot be diagnosed as defective prior to transport).

The subsequent paragraph and indents are also amended to read:

Lithium ion cells or batteries and lithium metal cells or batteries identified as being damaged such that they do not conform to the type tested according to the applicable provisions of the UN Manual of Tests and Criteria are forbidden for transport. For the purposes of this special provision, these may include, but are not limited to: a) cells or batteries that have leaked or vented; b) cells or batteries that cannot be diagnosed prior to transport; or »