[ID] => 7454
[post_author] => 34
[post_date] => 2017-01-03 16:57:05
[post_date_gmt] => 2017-01-03 16:57:05
[post_content] => The Working Group of the International Civil Aviation Organisation’s (ICAO) Dangerous Goods Panel (DGP) held its 2016 meeting this past 17 to 21 October in Montreal. In practice, this was the first meeting to discuss proposals for changes and additions to the ICAO Technical Instructions for inclusion in the 2019-2020 edition; as it took place prior to the final meeting of the UN Sub-committee of Experts on the Transport of Dangerous Goods for the biennium and the subsequent agreement of the 20th revised edition of the UN Recommendations, the meeting occupied itself largely with proposals specific to the transport of dangerous goods by air.
Also, being the first meeting of the biennium for the DGP experts, there was no pressure to make firm decisions on any of the proposals. There were few issues of any great significance although – somewhat predictably – the thorny issue of lithium batteries will not go away.
Indeed, the problem of getting battery manufacturers and shippers to comply with the provisions of the Technical Instructions (TIs) regarding lithium batteries was behind a proposal that the TIs be made freely available on the ICAO website. Easier availability of the TIs, it was argued, could only improve compliance rates. Other modal regulations are also freely available for download, as are the UN Recommendations.
This suggestion received unanimous support from delegates; however, there are financial issues to consider – DGP’s work is, after all, partly funded through revenues from sales of the TIs – and this cannot be seen in isolation. The ICAO Assembly has already been discussing making standards and recommended practices available to all and the TIs are part of that discussion. The ICAO Council has been asked to look at the issue and report back to the next session of the Assembly.
Another proposal relating to lithium batteries called for greater collaboration between DGP and the Aviation Security Panel (AVSECP) in order to explore possible measures for identifying undeclared lithium batteries in air transport. Not surprisingly, this received unanimous support.
ANNEX 18 REVISION
Annex 18 to the Chicago Convention contains the Standards and Recommended Practices applicable to the safe transport of dangerous goods by air, which are amplified in the TIs. Over the past year, the DGP Working Group on Reporting has identified some areas where Annex 18 would benefit from greater alignment with Annex 19 on safety management. It was proposed that a working group be set up to look at restructuring Annex 18 to clarify the responsibilities States have with respect to the transport of dangerous goods by air. This was unanimously supported, although several Panel members believed it would take many years to achieve.
Another paper proposed a review of Annex 18 to recognise entities in the air cargo supply chain other than shippers and operators (eg freight forwarders, handling agents, etc). It noted that when the TIs were originally drawn up, it was sufficient to mention only shippers and operators but that, since then, the nature of the industry has changed. While some Panel members expressed support for this, others were concerned that their national legislation could not extend beyond shippers and freight forwarders. It was agreed to form a working group to consider what revisions would be necessary.
The Working Group was also asked to consider adding a definition for “shipper” in the TIs. The shipper plays an important role, not least in certifying that a consignment is in proper condition for carriage by air, yet there is no definition in 1;3.1 to specify who has that responsibility. Many Panel members thought this was a significant omission, particularly when other entities such as “freight forwarder” and “operator” were defined terms and other modes had definitions for “consignor”.
However, the proposal as it was made received little support, with many believing it could cause more problems than it solved. For example, any entity involved in the transport of dangerous goods prior to acceptance by the operator is subject to the shipper’s responsibilities and to have a definition of ‘shipper’ could lead to an undesired limitation on its applicability. Furthermore, in many cases there is no single ‘shipper’ – different individuals are usually responsible for packing, labelling and completing the documentation.
The European Chemical Industry Council (Cefic) proposed that medicines meeting the criteria of dangerous goods, which are manufactured and packaged for retail sale, should be excepted from the requirements of the TIs, in the same way they are in the European dangerous goods regulations for transport by road, rail or inland-waterways. There was no support for the proposal, which would cause multimodal disharmony as there is no similar exemption in the UN Model Regulations nor the International Maritime Dangerous Goods (IMDG) Code; furthermore, the proposal would effectively deregulate dangerous goods based on end use, which is not commonly done.
A recent fatal accident involving an unserviceable aircraft tyre that had been shipped fully inflated generated some discussion as to the precise meaning of “completely deflated” in Special Provision A59. Can an aircraft tyre that is no longer serviceable be shipped with some residual pressure, or must the tyre be completely deflated to ambient pressure, for example by removal of the valves?
It was proposed that A59 be amended to indicate an upper gauge pressure limit of 200 kPa at 20˚C, the same threshold for the classification of Division 2.2 gases. This was agreed.
A proposal to clarify that dangerous goods shipped as consumer commodities (ID 8000) in accordance with Packing Instruction Y963 can take advantage of the alleviation applicable to other dangerous goods regarding orientation arrows was also agreed.
A problem had been perceived with the provisions in 7;126.96.36.199, which specifies the requirements that apply to the loading of packages of dangerous goods bearing the ‘cargo aircraft only’ label. It was queried whether packages of dangerous goods permitted on both passenger and cargo aircraft and subject to the same net quantity limitations should be subject to the provisions of 7;188.8.131.52 even if they do not bear the ‘cargo aircraft only’ label. Text was proposed to address the perceived issue but the Working Group failed to see that there was a problem and did not agree any change was necessary.
Another problem with the ‘Cargo aircraft only’ label arises in Part 5;3.2, where it is required that the label be placed on the same surface of the package as the hazard warning label(s). This can result in the use of a much larger packaging than is appropriate for the contents. It was proposed that there should be a smaller label for instances when there is insufficient room to include all the labels on the same side of a packaging. This idea was not supported but it was felt that consideration should be given to allowing labels to be “next to each other”, which does not necessarily mean on the same side of a packaging, as is already the case for labels for primary and subsidiary risks. A revised paper will be prepared for the next meeting.
The Dangerous Goods Advisory Council (DGAC) had put forward a proposal to the UN Sub-committee of Experts on the transport of dangerous goods to amend the excepted quantity limits for UN 1219 isopropanol. At present that substance is assigned the E code E2, allowing inners of 30 ml and outers of 500 ml; however, the health care industry regularly consigns 1 ml ampules of isopropanol for sterilisation purposes in batches of 1,000. The UN experts had not accepted the proposal but suggested DGAC put it to ICAO for consideration. In the event, the Working Group felt the same way and declined to make the requested change.
Three papers raised issues relating to the transport of radioactive materials. The first highlighted issues concerning the arrangements that must be made between shippers and operators when transporting radioactive material under exclusive use. The working group agreed there were issues that needed to be addressed and the Secretary will take the matter to the International Atomic Energy Agency (IAEA).
IAEA will also be asked to look at the use of freight containers as “packaging” for radioactive materials. There are ambiguities in the current text that lead to inconsistencies in application.
A revision to the text of the definition for Approval for transport of radioactive material was proposed on the basis that there is a conflict between approvals and exemptions applicable to all dangerous goods when compared to the approvals specifically related to radioactive material. This seems to be an editorial issue. The proposer undertook to consider comments made and return with a revised proposal at the next working group meeting.
Not surprisingly, a large number of papers addressed issues relating to lithium batteries. The first of these raised issues with active baggage tags powered by small lithium metal cells. At a previous meeting of the Panel provisions had been agreed but ICAO decided not to adopt the agreed text until the matter had been considered by the Airworthiness Panel, primarily with regard to the possibility of interference with aircraft systems. This latest proposal was made on the basis that the devices are already being widely used and provisions are urgently required. The proposal was agreed with the caveat that the issue would again be raised with the Airworthiness Panel and reviewed in light of any feedback received from them.
A second paper concerned portable electronic devices that contain more than one lithium battery. When carried onboard an aircraft by an operator (e.g. to provide inflight entertainment), such equipment may not exceed what was permitted to be carried by passengers i.e. 160 Wh. Some operators carry equipment that contains several batteries and the paper suggested the aggregate of the batteries should be considered i.e. the Watt hour rating of all batteries combined should not exceed 160 Wh, rather than multiple batteries which could each be up to 160 Wh. Although there was no support for the proposal it was agreed that the conditions under which operators carry lithium battery powered equipment was worthy of review.
Another proposal initiated debate on introducing requirements for segregating lithium batteries from flammable dangerous goods. While some thought this reasonable, several difficulties were raised, including the fact that this would result in higher densities of batteries being loaded in other areas on the aircraft and that similar thought would need to be given to allowing a shipper to pack lithium batteries and flammable dangerous goods in the same package. No decision was taken, but members were encouraged to give the matter further though ahead of the next meeting in March.
The working group was invited to revise the provisions for spare lithium metal batteries carried with portable medical electronic devices in baggage, which, subject to operator approval, can be larger than those carried with other, non-medical, devices. The proposer suggested the current wording allows an unlimited number of spare batteries to be carried even if no medical device is carried. The working group understood the intent of the proposal but did not believe any amendment was necessary; it had been agreed previously that alleviations were appropriate for those with medical needs.
A proposal to delete the Section IB and II provisions for both lithium ion and lithium metal batteries when shipped on their own (i.e. not in or with equipment) received no support, it being pointed out that significant changes had only been introduced in April 2016 and many believed that those provisions should be given time to take effect.
A proposal to add a new emergency response drill code for lithium ion and lithium metal batteries was unanimously supported; these will now be assigned to drill code 12FZ.
A proposal to include additional mitigation measures for lithium batteries on cargo aircraft, including requiring loading in a hold with a fire suppression system, was felt to be premature given the work currently being done on this topic. It also had to be considered that cargo aircraft are not required to have a fire suppression system and the proposal could result in lithium batteries not being shipped by air at all. The paper was withdrawn.
Discussion was invited on whether there should be a Watt hour rating limit for lithium ion battery-powered mobility aids; unlike other battery-powered equipment carried by passengers there is no limit to what size a battery could be in a mobility aid (other than in collapsible devices where a limit of 300 Wh applies). The working group agreed this was a very difficult issue – what level could be regarded as “safe”? – and undertook to give it consideration ahead of further debate at the next meeting.
The introduction of the 30 per cent state of charge limit has raised questions. For instance, does it apply to the battery as a whole or to individual cells? Can some cells have a state of charge in excess of 30 per cent and others less, resulting in an overall compliant state of charge? It was clarified that the limit applies to the battery as a whole; it would be impossible to test individual cells and, in any event, it is extremely unlikely that the state of charge of individual cells would be significantly different.
A proposal was put forward to allow the State of Origin, when issuing an exemption for the carriage of explosives, not to require full compliance with all marking and labelling requirements when the goods are in an overpack. The proposal evidently stemmed from a problem arising from the failure of consignors to comply with the TI provisions in that regard. The Working Group could see no justification in allowing consignors leeway under the TIs simply on the basis that they are not compliant and the proposal was rejected.
A proposal to allow the Notification to Captain (NOTOC) to be in electronic form sparked some debate. The current requirement was that the NOTOC must be in “written or printed” form. The International Federation of Airline Pilots' Associations (IFALPA) had no objection to the proposal if a paper copy were to be provided as well, citing concerns about loss of power in an emergency that may prevent access to electronic information. Other members believed it should be up to the operator to decide how best to provide the information. The proposer undertook to return with a further proposal at the next meeting.
A straightforward proposal to require the date of flight on the NOTOC was agreed.
PASSENGER AND CREW BAGGAGE
A proposal to increase the maximum quantity of ammunition cartridges that passengers could carry, to recognise the amounts needed by competitive shooting teams, received little support. It was suggested that any increase should be based on a risk assessment, not end use.
The working group was asked to consider how to identify articles that are capable of producing a dangerous evolution of heat. Such articles are not permitted in baggage but it is very difficult for passengers to know whether an article would meet this criterion. No one had a ready solution but members were asked to give this some thought prior to the next meeting.
Following discussion at the previous meeting of DGP, a paper proposed revisions to the provisions for the loading of battery powered mobility aids. This is a complex subject and a decision was put off pending discussion at the next meeting.
Another paper proposed revisions to simplify the provisions for dangerous goods carried by passengers and crew in Part 8. This was well received by the working group and a further proposal will be made at the next meeting.
Prompted by a submission from the Air Traffic Management Requirements and Performance Panel (ATMRPP), the Working Group was invited to comment on the potential benefits (or otherwise) of including details of dangerous goods carried on an aircraft on the associated flight plan.
It was felt that the proposals went far in excess of what could help in the event of an emergency, or even what would likely be available. There was little support for the introduction of such a requirement, which would pose great operational difficulties for little if any safety benefit.
The Working Group was alerted to a new method of avalanche control, which involves the use of a hydrogen/oxygen unit slung from a helicopter. It was invited to change 1;184.108.40.206 to reflect this. The Working Group decided to reflect on the proposed addition in case it would make unwanted changes.
There was general sympathy for a proposal to forbid the practice of applying hazard warning labels when a package does not contain dangerous goods. However, no agreement could be reached on how the matter should be resolved, with some believing that any such requirement would effectively result in the regulation of non-dangerous goods, which was outside the scope of the TIs. The proposer undertook to canvass opinion and possibly return with a revised proposal at the next meeting.
A paper on the current provisions related to dangerous goods that may be carried by an operator without the full provisions of the TIs being applied (e.g. items for retail sale or use onboard the aircraft) invited comments for a future working paper.
The Working Group was advised that recent changes in the TIs in respect of the transport of infected live animals had highlighted anomalies in the UN Model Regulations. Further comments were sought outside of the meeting with a view to bringing this to the attention of the UN Sub-committee.
The official report of the DGP Working Group’s September 2016 meeting can be found on the ICAO website
* Geoff Leach was formerly head of the UK Civil Aviation Authority’s Dangerous Goods Office and chairman of the ICAO Dangerous Goods Panel. He is now principal of the Dangerous Goods Office Ltd and attends Panel meetings as a representative of the Dangerous Goods Advisory Council.
[post_title] => ICAO: In-flight service
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[post_name] => icao-flight-service
[post_modified] => 2017-01-03 16:57:05
[post_modified_gmt] => 2017-01-03 16:57:05
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