Hazardous Materials

Safe Shipments of Hazardous Materials/Dangerous Goods

Improving the Safety of Lithium Batteries Shipped by Air

ALPA has long advocated for improved transport requirements for hazardous materials (hazmat). Mitigating the risk to aviation safety from dangerous goods requires a focus on two specific areas: improving hazmat regulations and eliminating shipments of undeclared hazmat.

Improving the Safety of Lithium Batteries Shipped by Air

As witnessed in 2015 with hoverboards, and again in 2016 with the Samsung Galaxy Note 7, lithium batteries and other hazmat can create real safety threats in the absence of proper regulation. 

The significant consumer demand for this high-density power source has resulted in rapid expansion in lithium battery production, supply, and proliferation (knockoff batteries). Consequently, this hazard is increasing exponentially. While lithium batteries represent a significant technological improvement over older battery technology, their high energy density and flammability make these batteries more prone to failure, resulting in fire and explosion. The lack of comprehensive hazardous materials regulations for the carriage of lithium batteries as cargo onboard commercial aircraft, both passenger and cargo, continues to pose risks to air transportation.

New standards implemented by the International Civil Aviation Organization (ICAO) on April 1, 2016, made significant improvements to provisions under which lithium batteries are shipped as cargo by air around the globe. While the 2018 FAA Authorization Bill requires the Department of Transportation to harmonize U.S. regulations with the ICAO standards, a proposed rule has not been issued yet. Additionally, ALPA does not believe that the ICAO standards go far enough to fully address the safety risk created by lithium batteries. Work must continue to develop and mandate performance-based packaging standards that will prevent and/or contain a lithium battery fire. These standards must also address the threat from external fires.

In the FAA Modernization and Reform Act of 2012 (P.L. 112-95), Section 828, Congress directed the DOT not to regulate lithium batteries carried as cargo on aircraft stricter than the ICAO standards unless a fire onboard an aircraft could be proven to have substantially contributed to a fire involving lithium batteries in the cargo hold. There have now been three such accidents (UPS 1307, UPS 6, and Asiana 991), two of which were fatal to the pilots on board, and all three of which destroyed the aircraft. The facts attribute lithium batteries as a large factor in all of these accidents.

The National Transportation Safety Board (NTSB), following the last accident involving Asiana Airlines Flight 991, issued a safety recommendation stating that it “believes that the circumstances and findings in the Asiana Flight 991 accident constitutes such credible evidence that demonstrates a deficiency in cargo-segregation requirements that would permit the HMR [hazardous materials regulations] to be changed to be more stringent than the current ICAO requirements.”

ALPA agrees with the NTSB that the threshold set by legislation has been met and it is time to move forward on comprehensive regulations governing cargo shipments of lithium batteries.

NTSB Calls for Stronger Lithium Battery Regulations Over Fire Risk

Eliminating Shipments of Undeclared Hazmat

Hazardous materials (liquids, flammables, and other materials) shipped as cargo without being identified by the shipper are considered “undeclared” hazardous materials. There are no official estimates of what percent of parcel shipments contain undisclosed hazmat; however, the FAA tracks reported incidents where hazmat shipments create safety hazards for various reasons, such as a leaking package or other type of external evidence that the package is a safety concern. In 2017, the FAA received 1,082 reports of such events, and 479 of the incidents involved undeclared hazmat.

ALPA’s work to eliminate undeclared hazmat has resulted in the “Check the Box” campaign, which was developed by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to educate shippers on how and when to properly identifying hazmat in packages. PHMSA kicked off this program at ALPA’s 2018 Air Safety Forum.


  • Improvement to the Hazardous Materials Regulations should at a minimum:
    • Provide lithium batteries with the full range of safety protections afforded other hazardous materials transported by air; and
    • Define special packaging requirements for lithium batteries when shipped as cargo by air and include provisions to account for the threat from an external fire.
  • The U.S. DOT should require shipper verification that the package, cargo, or freight being submitted for transport does not contain dangerous goods or hazardous materials.
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