All commercial air operators and private operators
|Issuing Office:||Flight Technical and Operator Certification|
|File Classification No.:||Z 5000-35 U|
|Document No.:||CASA 2016-04|
This purpose of this CASA is:
- To alert all commercial air operators and private operators of Protective Direction (PD) No. 35 issued under section 32 of the Transportation of Dangerous Goods (TDG) Act, 1992;
NOTE: A copy of PD No. 35 can be found at: https://tc.canada.ca/en/dangerous-goods/protective-directions
- To inform operators of a recently published U.S. Federal Aviation Administration (FAA) Safety Alert for Operators (SAFO) 16001 dated January 19, 2016;
- To provide appropriate Recommended Actions to all commercial air operators and private operators.
NOTE: This CASA only addresses the transport of lithium batteries as cargo on passenger and cargo aircraft. This CASA does not apply to the transport of lithium batteries contained in or packed with equipment or electronic devices or to the carriage of lithium batteries by passengers and crew.
For the purpose of this CASA, lithium batteries include, lithium ion batteries and lithium metal batteries:
- Lithium Ion Batteries. (UN3480). These are rechargeable lithium batteries, similar to those found in cameras, cell phones, laptop computers, and radio-controlled toys. Lithium polymer batteries are types of lithium ion batteries.
- Lithium Metal Batteries. (UN3090). These are lithium batteries that cannot be recharged and are designed to be discarded once their initial charge is used up.
Transport Canada (TC) has published PD No. 35 to prohibit the transport by air of dangerous goods UN3480, LITHIUM ION BATTERIES as cargo on passenger aircraft as of April 1st, 2016.
NOTE: TC already prohibits the transport of lithium metal batteries (UN3090) as cargo on passenger aircraft.
In addition, PD No. 35 requires that if lithium ion (UN3480) and lithium metal (UN3090) batteries are offered for transport or transported as cargo on cargo aircraft, they must meet the provisions of Packing Instruction 965 or 968, as the case may be of the International Civil Aviation Organization (ICAO) Technical Instructions.
PD No. 35 will remain in effect until the TDG Regulations are modified to incorporate these changes or until the day it is cancelled in writing by the Minister of Transport.
NOTE: The term air carrier(s), as used in PD No. 35 applies to all commercial air operators and private operators.
NOTE: For the purposes of this CASA, any aircraft carrying passengers including a passenger/cargo combination (Combi) aircraft is considered to be a passenger carrying aircraft.
In January 2015, Transport Canada Transportation of Dangerous Goods Directorate updated its website with information relating to the transportation of lithium batteries (https://tc.canada.ca/en/dangerous-goods/shipping-importing-devices-containing-lithium-batteries).
On January 19th, 2016, the Federal Aviation Administration (FAA) published Safety Alert for Operators (SAFO) 16001 to alert US operators on the risks of fire or explosion when transporting lithium ion or lithium metal batteries on passenger and cargo aircraft.
- FAA SAFO 16001, Risks of Fire or Explosion when Transporting Lithium Ion or Lithium Metal Batteries as Cargo on Passenger and Cargo Aircraft
The Recommended Action of the SAFO is stated as follows:
“Before air operators engage in the transport of lithium ion or lithium metal batteries on cargo aircraft, be aware that ICAO and major airframe manufacturers (Boeing and Airbus) have recommended that operators perform safety risk assessments in order to establish whether, or how, they can manage the risk associated with the transport of these batteries. The FAA strongly supports these recommendations. The FAA encourages those operators who have previously performed a risk assessment to re-evaluate their assessment in light of the further evidence gained through the recent testing of lithium batteries. Operators that have implemented a formal Safety Management System (SMS) should accomplish a Safety Risk Assessment (SRA), in accordance with the Safety Risk Management process in its SMS.”
In addition to the SAFO, aircraft manufacturers Airbus and Boeing, the European Aviation Safety Agency (EASA), and ICAO, have also recently published material on the risks associated with the transport of lithium batteries. These references include the following:
- Airbus operators can reference Airbus In-Service Information publication, ISI 00.00.00182, dated July 24, 2015;
- Boeing operators can reference Boeing Multi Operator message, MOM-MOM-15-0469-01B, dated July 17, 2015;
- EASA Safety Information Bulletin – Operations – SIB No.: 2015-19; 05 October 2015; Transport of Lithium Batteries as Cargo by Air.
- ICAO Electronic Bulletin, EB 2015/48; AN 11/2.1; 15 September 2015.
In consideration of all data and information currently available on carriage by air of lithium batteries, TC has determined additional risk mitigation measures, in addition to those required by PD No. 35, are necessary for the safe transport of lithium ion batteries (UN3480) or lithium metal batteries (UN3090) aboard cargo aircraft.
TC recommends that in addition to the requirements of PD No.35, operators develop risk mitigation measures before transporting lithium batteries as cargo on cargo aircraft.
Operators should perform a Safety Risk Assessment (SRA) in consideration of the information provided by this CASA. This SRA should be in accordance with the Safety Risk Management process of the operator’s SMS (for those operators having an SMS in place.)
TC encourages those operators who have previously performed a risk assessment to re-evaluate their assessment in consideration of the information provided within this CASA.
When considering risk mitigation measures, TC recommends that operators who wish to transport lithium batteries as cargo on cargo aircraft, review and consider the following:
- The packaging and shipping requirements for dangerous goods per TDG Regulations;
- The density of packages of lithium batteries and cells;
- The training of personnel who handle and transport lithium batteries, including information on the dangers associated with any lithium battery; the proper labeling; the proper loading; the proper rejection criteria for damaged shipments; and emergency response procedures in the event of a heat/smoke/fire event involving lithium batteries;
- The types, quantities and the frequency of transport of lithium batteries (including state of charge of the battery, if known);
- Evaluation of the fire protection features of each model of aircraft they operate;
- The operator’s specific lithium battery acceptance requirements for packaging, state of charge, and any other limitations placed upon the shipper;
- The history of the shipper’s compliance with TDG Regulations;
- The means of loading and limitations on lithium battery shipments within the cargo compartment of cargo aircraft;
- The containment characteristics of Unit Load Devices (ULD);
- The specific hazards and safety risks associated with each lithium battery and cell type to be carried alone or in combination;
- The chemical composition of the lithium batteries and cells;
- Location of lithium batteries in the cargo compartment, including:
- Proximity to other lithium batteries, and
- Proximity to other dangerous goods;
- Notification procedures for the flight crew:
- Location of the lithium batteries in the cargo compartment;
- Accessibility of the lithium batteries to the crew;
- Quantity of items being shipped;
- The capability of the crew to fight an in-flight lithium battery fire.
For more information concerning this issue, contact a Transport Canada Centre; or contact Christopher Florence, Flight Technical and Operator Certification, Commercial Flight Standards, in Ottawa, by telephone at 613-998-9424 or by e-mail at firstname.lastname@example.org.
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