Safety Risk Assessment (SRA)

Carriage of Lithium Batteries

Version 1
January, 2016

Carriage of Lithium Batteries

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Carriage of Lithium Batteries

Background
The carriage of Lithium Batteries has been identified as an emerging risk to airline operations.
Although there is little data, due to the potential catastrophic outcome of a lithium battery
thermal runaway resulting in an onboard fire, there is Industry pressure to ban the carriage of
lithium batteries on commercial aircraft.
A unilateral ban is not conducive to the performance-based system Industry has adopted, and
IATA believes that this risk must be treated as any other. As such, aligned with SMS
methodology, IATAs recommendation is that each carrier conduct a safety risk assessment
based on the nature of their operation.
To facilitate this task, IATA has produced this Safety Risk Assessment (SRA) evaluating
Industry-wide fundamentals with respect to the carriage of lithium batteries. Considering some
existing risk assessments and bow-tie analysis as well as latest developments, including battery
testing and analysis, this document highlights potential failure modes, and possible mitigations.
The intent is that this document will formulate the basis from which individual carriers can
complete their respective safety risk assessments.

Regulation
Lithium batteries are classed as Dangerous Goods. As such, there are international regulations
that prescribe the quantity and make-up of lithium batteries for commercial aircraft carriage.
This is contained in the Dangerous Goods Regulations, The Technical Instructions for the Safe
Transport of Dangerous Goods by Air and the UN Model Regulations.

Working Group
Derived from a request by the IATA Director of Safety, a small working group was formulated to
identify and document risks associated with the carriage of lithium batteries, in order to identify
Industry-wide risks. This group was also tasked to formulate a template to facilitate Operators
in conducting their own risk assessments to ensure an acceptable level of safety is maintained
at all times during this specific type of operation.
Following are the names and titles of those who prepared this SRA.
Nancy Rockbrune ~ Head of SMS, IATA
David Tindley ~ Manager Safety, IATA
Dave Brennan ~ Assistant Director, Cargo Safety and Standards, IATA
The document is submitted for the purpose of maintaining safe operations while carrying
lithium batteries onboard.

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Carriage of Lithium Batteries

Risk Assessment
The completed risk matrix, including mitigation actions is documented in Appendix A.

Assumptions
This SRA follows the recommendations and methodology of IATA and the IATA Safety Group in
encouraging operators to conduct an SRA concerning the carriage of lithium batteries on their
commercial aircraft.
The ICAO Risk Model, as documented in Doc 9859, Safety Management Manual (SMM) Ed.3,
was used to conduct this SRA.
Test results and incident statistics for quality compliant lithium battery manufacturers and
shippers, provided to IATA by the PRBA, the Rechargeable Battery Association, and NEMA, the
National Electrical Manufacturers Association, formulated the risk rating for the probability of an
occurrence in the SRA.
SRAs should be reviewed and updated accordingly to reflect advances in scientific study,
operational data and / or Regulatory changes.

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Carriage of Lithium Batteries

Accident Analysis
Over the last ten years there have been three aviation accidents where lithium batteries were
known, or suspected, to have been involved in a significant way.
Of these accidents, only one was attributed, with reasonable certainty, to a fire in a cargo
container which held thousands of lithium batteries. Some of which were not properly declared
or accompanied with Test Reports in compliance with the UN Recommendations on the
Transport of Dangerous Goods Manual of Tests and Criteria, Section 38.3, to verify that the
battery designs were in conformance with UN Modal Regulations.
Another of the accidents had a fire that broke out in the area where dangerous goods, including
lithium batteries, were stored, however it was impossible for investigators to determine with
certainty the source of the fire. For the third accident, it was determined that the fire started
elsewhere in the cargo hold and spread to the container containing lithium batteries.
For all three incidents, it is evident that once there is a fire with large quantities of lithium
batteries, the time from ignition to uncontrollable fire is quite short ~ 17 minutes, 23 minutes
and 27 minutes respectively. However, it must be noted that each of these incidents are in the
context of large quantities of lithium metal and/or lithium ion batteries.
The report, including an Executive Summary, detailing the specifics of each accident is
documented in Appendix B.
Please note, that due to the small number of accidents in relation to the number of passenger
and cargo flights operated over this ten year period, an accident rate has not been calculated.
Additionally, since there is no way to determine declared vs. undeclared carriage of lithium
batteries, it was impossible to determine a rate based on carriage and related incidents.
The following provides comparative details from the accident reports.

Accident/Incident #1
Asiana B744
Jeju

Accident/Incident #2
UPS B744
Dubai

Accident/Incident #3
UPS DC-8
Philadelphia

LI batteries on
board

Yes

Yes

Yes

Declared?

Yes

No

Lithium Yes
Other items no
(not considered a factor)

Hull loss

Yes

Yes

Yes

Fatalities (%)

2 (100%)

2 (100%)

0 (0%)

Phase of flight

Early cruise

Early cruise

Descent

50 minutes

22 minutes

c. 2 hours

17 minutes

23 minutes

27:45 minutes

Time into
flight
Time to
uncontained
fire

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Carriage of Lithium Batteries

Supporting Documentation

ICAO SMM ~ Doc 9859, Edition 3

Dangerous Goods Regulations (DGR) ~ 2015 (56th edition)

Technical Instructions for the Safe Transport of Dangerous Goods by Air Doc 9284 ~
2015-2016 Edition
o

Addendum No. 3 to the 2015-2016 edition of the Technical Instructions to

address the changes applicable to lithium batteries

United Nations Recommendations on the Transport of Dangerous Goods, Model

Regulations (Revision 19) ~ July 2015

IATA Lithium Battery Risk Mitigation Guidance for Operators 1st Edition ~ January 2015

Conclusion
The carriage of lithium batteries on commercial aircraft poses a risk. Although the probability of
an event occurring is extremely low, the severity of such an incident is high. As such, it is
recommended that operators perform a safety risk assessment, in order to manage these risks,
on passenger or cargo aircraft, to an acceptable level of safety, within their own specific
operation.
In order to perform such a safety risk assessment, information on the types and quantities of
lithium batteries and cells being transported would need to be considered. In addition, the
capabilities of the available fire protection system should also be taken into account.
Following on from such a safety risk assessment, the operator would be able to implement
effective mitigations that address the risks pertaining to the carriage of lithium batteries,
specific to their operation.
Millions of lithium batteries are transported around the globe everyday with no incident. There
are a number of quality controls around the product in place. The risk to the safety of aircraft
operations due to the carriage of lithium batteries is primarily driven through non-compliant
shippers / shipments. It is believed that an industry-wide ban on the carriage of lithium
batteries would introduce an intolerable risk to aviation as it would not act as a deterrent for
those already operating outside of regulations. In fact it would make it more profitable for those
operators while also eliminating the need for Industry vigilance to mitigate against such
operators.

Recommendation
Commercial Operators that carry lithium batteries on their aircraft should conduct a thorough
risk assessment, in order to ensure that effective controls are in place to mitigate the risk to an
acceptable level.
Industry must remain committed to sharing information, and conducting further scientific
research with the purpose to improve the knowledge and understanding on this important topic.

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Management of Carriage of Lithium Batteries As Cargo

Safety Risk Register ~ Appendix A
A

Hull Loss

Existing Controls

Extensive battery testing

aligned with regulatory
requirements

Shipped in accordance with

DGR and IATA LI Battery
Guidance

Rating

Mitigation Action

Specific fire containment

strategies for LI batteries

Tolerable
(with mitigation)

Ownership

OEMs and
ICAO / DGP

New Controls

Severity

Internal failure leading

to thermal runaway
causing onboard fire

Consequence
(worst case scenario)

O
Risk

Probability

Battery Quality
OEMs applying QMS

Hazard

Severity

No. Event
2
3
4

H
Risk

Probability

Rating

Acceptable

Tolerable
(with mitigation)

State oversight

Limitation of battery quantities ICAO DGP /

per pack / consolidated pack / IATA DGB
per aircraft

Operator compliance with

regulations and internal
oversight

Specific fire containment

strategies for LI batteries

OEMs and
ICAO / DGP

State oversight

Screening of shipments from

known problem areas

State /
Operator and
Shippers

Oversight

System of registering known

shippers

State

State oversight

Onboard fire suppression

5
Counterfeit / Untested
Batteries

Internal failure leading

to thermal runaway
causing onboard fire

Hull Loss

Unknown / non-existent
testing

3*

Intolerable

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SAMPLE

Management of Carriage of Lithium Batteries As Cargo

Safety Risk Register ~ Appendix A
A

Hull Loss

Existing Controls

Rating

Limit quantities in accordance

with DGR

Mitigation Action

Further limit quantities to be

shipped

Ownership

ICAO DGP

New Controls

Severity

Battery failure or
external heat source
leading to thermal
runaway causing
onboard fire

Consequence
(worst case scenario)

O
Risk

Probability

Type of Battery
Li Metal

Hazard

Severity

No. Event
2
3
7

H
Risk

Probability

Rating

Tolerable
(with mitigation)

Acceptable

State oversight

Fire resistant packaging

3*

Intolerable

Onboard fire suppression

systems
Performance standards

8
LI Ion

Battery failure or
external heat source
leading to thermal
runaway causing
onboard fire

Hull Loss

Limit quantities in accordance

with DGR

Further limit quantities to be

shipped

ICAO DGP

State oversight

Battery state of charge in

Shipper
accordance with requirements
2

Tolerable
(with mitigation)

Fire resistant packaging

ICAO DGP
Onboard fire suppression
systems

ICAO DGP

Performance standards

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SAMPLE

Management of Carriage of Lithium Batteries As Cargo

Safety Risk Register ~ Appendix A
A

Battery failure or short- Hull Loss

circuit leading to
thermal runaway
causing onboard fire
unable to be
suppressed by onboard
suppression

Existing Controls

Rating

Mitigation Action

Limit quantities in accordance

with DGR

System of registering known

shippers

Acceptance checks

Screening

Battery SoC in compliance

with requirements

Overpack limits
3*

Ownership

New Controls

State

State oversight

Operator

Operator internal program

Freight
Forwarder

Security screening
enhancements

Intolerable

Severity

Consequence
(worst case scenario)

O
Risk

Probability

Shipper / Freight Forwarder

Shipping large bulk
(excessive) quantities
of LI batteries not
packed in accordance
with DGR)

Hazard

Severity

No. Event
2
3
10

H
Risk

Probability

Rating

Tolerable
(with mitigation)

Tolerable
(with mitigation)

Tolerable
(with mitigation)

Consolidation limits
Aircraft limits
FCC/FRC use

11
Undeclared and
misdeclared lithium
batteries

Unknown quantity /
quality including
packaging and
build/design leading to
fire

Hull Loss

Security Screening Freight

Forwarder Documentation
review

System of registering known

shippers

State
Operator

Screening

Enhanced Freight Forwarder

Participation

3*

Intolerable

Freight
CONTROL NEEDED (e.g.. X- Forwarder
Ray, thermal imaging ???)

Safety screening of advanced

data

FCC/FRC use

12
Freight Forwarder
consolidation of
shipments (quantity of
batteries shipped)
7

Battery failure or short- Hull Loss

circuit leading to
thermal runaway
causing onboard fire
unable to be
suppressed by onboard
suppression

Effective April 2016:

Tolerable

Overpacks forbidden

State oversight
Operator internal program

Limit of 1 package
Package = no more than 8 Liion cells or 2 Li-ion batteries

ICAO DGP /
IATA DGB

(Risk level is
dependent on
new packaging
limits
demonstrating
desired effect )

Security screening
enhancements

13

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SAMPLE

Management of Carriage of Lithium Batteries As Cargo

Safety Risk Register ~ Appendix A
A

Battery failure or short- Hull Loss

circuit leading to
thermal runaway
causing onboard fire

Existing Controls

Rating

Screening for package

damage at acceptance,
buildup and loading ~
damaged packages not
loaded

Mitigation Action

Oversight of entire supply

chain

Ownership

New Controls

Severity

Consequence
(worst case scenario)

Rating

Tolerable
(with mitigation)

Tolerable
(with mitigation)

Tolerable
(with mitigation)

All stakeholders Increased awareness on

cargo type handling

Awareness and training to

increase staff vigilance
3*

O
Risk

Probability

Manual Handling
Shipment is damaged
through mishandling

Hazard

Severity

No. Event
2
3
14

H
Risk

Probability

Intolerable

Damaged batteries without

package damage
compromises existing
controls

Communication to increase
public awareness

Existing mitigations are

compromised through
unknown physical damage

Oversight of entire supply

chain

15
Battery is damaged
through mishandling

Battery failure or short- Hull Loss

circuit leading to
thermal runaway
causing onboard fire

All stakeholders Enhanced handling

procedures

Awareness and training to

increase staff vigilance

3*

Intolerable

Communication to increase
public awareness
CONTROL NEEDED (e.g.. XRay, thermal imaging ???)

16
Shipment is damaged
during shipment
acceptance, buildup
and aircraft loading

Battery failure or short- Hull Loss

circuit leading to
thermal runaway
causing onboard fire

Screening for package

damage at acceptance,
buildup and loading ~
damaged packages not
loaded

10

3*

Safety oversight (State /

Operator)

State /
Operator

Awareness and training and

staff vigilance

Operator /
RHA/GSP

Intolerable

Damaged batteries without

package damage
compromises existing
controls

Communication to increase
public awareness

17

State oversight / Operator

internal audit program / IOSA
/ ISAGO
No fault reporting for all
parties

Safety oversight

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SAMPLE

Management of Carriage of Lithium Batteries As Cargo

Safety Risk Register ~ Appendix A
A

Hull Loss

Existing Controls

Extensive battery testing

aligned with regulatory
requirements
Limitation of battery quantities
per pack

11

Rating

Mitigation Action

Specific fire containment

strategies for LI batteries

Ownership

OEMs and
ICAO / DGP

New Controls

Severity

Battery failure leading

to thermal runaway
causing onboard fire

Consequence
(worst case scenario)

O
Risk

Probability

Inflight Fire
Fire originating in
shipment

Hazard

Severity

No. Event
2
3
18

H
Risk

Probability

Rating

Tolerable
(with mitigation)

Tolerable
(with mitigation)

State oversight

Tolerable

Shipped in accordance with

DGR

Operator compliance with

regulations and internal
oversight

(Risk level is
dependent on
new packaging
limits
demonstrating
desired effect )

FCC/FRC use

Onboard fire suppression

19
Fire originating
elsewhere in hold

12

External heat source

leading to thermal
runaway causing
onboard fire

Hull Loss

Onboard fire suppression

Tolerable

Limitation of battery quantities

per pack
2

(Risk level is
dependent on
new packaging
limits
demonstrating
desired effect )

Specific fire containment

strategies for LI batteries

ICAO DGP

State oversight
Operator compliance with
regulations and internal
oversight
Development of performance
based specifications for the
segregation of batteries

20

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SAMPLE

Management of Carriage of Lithium Batteries As Cargo

Safety Risk Register ~ Appendix A
A

23
24

Total Ban ~ Consequential Risk

Carriage of lithium
Due to commercial
Hull Loss
batteries banned on all pressure batteries are
commercial aircraft
shipped anyway, either
undeclared or misdeclared. No
knowledge by operator
where in the aircraft
1
they may be, how
many, what types, etc.
As such no mitigations
in place. Battery failure
leading to thermal
runaway causing
onboard
fire.
Carriage of lithium
Due
to commercial
Hull Loss
batteries banned on all pressure batteries are
commercial aircraft
shipped anyway, either
undeclared or misdeclared. No
knowledge by operator
where in the aircraft
2
they may be, how
many, what types, etc.
As such no mitigations
in place. Battery failure
leading to thermal
runaway causing
onboard fire.

Version 0.5
January 2016

Existing Controls

Rating

Onboard fire suppression

Mitigation Action

Specific fire containment

strategies for LI batteries
Existing screening of
shipments
3*

100% screening of all cargo

New Controls

OEMs

State oversight

Operator and
Shippers

Oversight

Intolerable

Onboard fire suppression

3*

Ownership

Intolerable

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Operators

Severity

Consequence
(worst case scenario)

O
Risk

Probability

22

Hazard

Severity

No. Event
2
3
21

H
Risk

Probability

Rating

3*

Intolerable

Acceptable

Operator compliance with

regulations and internal
oversight

SAMPLE