Playing with fire: Undeclared dangerous goods
Despite the dramatic rise of battery-related freight and baggage fires over the last 20 years, the shipment of lithium batteries is simply one example of the thousands of potentially dangerous goods that are shipped without properly being identified. A stark illustration of how dangerous goods can cause a catastrophe if they are not prepared for transport in accordance with strict International Civil Aviation Organisation (ICAO) regulations occurred in May 1996 when a Valujet flight crashed killing all 105 passengers and 5 crew on board. This time it was not lithium batteries that caused the crash, but the improper carriage in the cargo hold of chemical oxygen generators, the devices used in the passenger cabin to provide oxygen in the event of depressurisation. While they do not pose a danger when fitted to the aircraft in normal usage, if the generator comes into contact with any combustible material, such as packaging, it can (and did) ignite.
A growing risk
Unfortunately the risk of such a fire has grown considerably in recent years due to the surge in the shipment of undeclared dangerous goods that constitute potential fire hazards. These include new and used electronic products containing lithium batteries, smokeless cigarettes, fireworks, gunpowder and even model rocket engines. Sold via online auction and retail web-sites such as eBay, the concern with shipping such items lies in the fact that frequently neither the seller nor the buyer has any understanding that these are considered dangerous goods. As they are not declared as dangerous goods, these potentially incendiary devices are not properly identified, and so are not safely packaged and positioned in the aircraft in accordance with dangerous goods regulations . Today, th e s e goods represent the biggest risk of fire in air cargo transportation, a risk that is increasing year -on-year as the popularity of Internet trading grows. IATA’s head of dangerous goods, David Brennan, described this worrying trend as “the Wild West of dangerous goods.” Perhaps most concerning of all, however, is his admission at this year’s IATA’s Wor ld Ca rg o Symposium that there is very little the industry can do about it. Geoff Leach, manager of the dangerous goods office at the UK’s Civil Aviation Authority comments: “The fact of the matter is nobody knows the real size of the problem. In the UK we receive around 1000 Dangerous Goods Occurrence Reports from airlines and their handling agents, the majority of which involve undeclared dangerous goods. What we don’t know, of course, is the number of undeclared dangerous goods which reach their destination without being detected. “What I can say however is that the number of reports received is increasing rapidly year-on-year, although a greater awareness of the reporting requirements may be contributing to this. Many dangerous goods are discovered as a result of x-ray screening for reasons of security (i.e it is not being done to detect dangerous goods per se), which is why it is so important that air cargo staff, including those responsible for security, are appropriately trained so they can recognise dangerous goods when they come across them. Apart from x-ray (which cannot detect all types of dangerous goods) or when dangerous goods become apparent in an incident, vigilance of cargo staff is really the only other way of detecting undeclared dangerous goods.”
No industry consensus
To compound matters further, there is no general consensus within the industry on how to properly tackle the issue. While some advocate educating consumers via the auction web-sites on the safe packaging of dangerous goods, others believe in educating the actual shippers of the products. And there are others still who believe in a programme combining increased awareness and education, and stiffer penalties for those who do not adhere to regulations. Even in the matter of penalties, there appears to be little consensus. Currently in the UK, when an undeclared dangerous item is discovered, most cases are dealt with via warning letters from the Civil Aviation Authority to the shipper of the product. In some situations, financial penalties are awarded – the largest penalty in the last 20 years was £95,000. But only once has a custodial sentence been imposed by a UK court. The US meanwhile is an altogether different story. The Federal Aviation Administration recently levied a civil penalty of $175,000 on MIT, alleging that the university shipped 33 devices with lithium batteries via FedEx in a box not labelled as hazardous materials. In this incident a package was discovered with smoke and flames coming from it while it was moving on a conveyor at the FedEx sorting facility. Because the package was not properly labeled and marked, Federal Express employees did not know the shipment contained hazardous material. They made several unsuccessful attempts to extinguish the flames with a fire extinguisher.
Lack of enforcement
But perhaps the heart of the problem lies in the fact that there are currently no universally enforceable regulations on the transportation of dangerous goods and lithium batteries. International rules (agreed by ICAO) still require regulation and enforcement at a national level, and different countries vary greatly in their interpretation of regulations and their commitment to enforcement. For example US rules currently under review differ significantly from ICAO’s. Following the MIT incident, safety officials have repeatedly raised concerns about lithium battery shipments, most recently with the International Federation of Air Line Pilots’ Association (IFALPA) asking for revised ICAO regulations for shipping the batteries. Perhaps the only issue that all parties agree upon is that it is simply not feasible to screen 100 per cent of all air cargo for hidden dangerous goods. Not only would it take far too much time to implement, it would be economically disastrous. What’s more, screening by itself is not and ever will be 100 per cent reliable. While sophisticated screening, intelligence systems and sniffer dogs have been proven to detect explosives and terrorist threats, this is less effective for uncovering common household items and electronics, which could potentially pose a fire risk due to malfunction or inadequate packaging. All of this begs the following questions:
• Should freighter fire protection be solely reliant on prevention through screening and intelligence?
• Should safety remain at risk while we wait for the right kind of technology to be implemented everywhere to ensure 100 per cent effective and efficient cargo screening?
• Should we trust that all participants from professional companies to amateur traders, in the highly competitive, cost-driven, global supply chain will know about and comply with aviation regulations?
• Can aircraft not be physically protected from a cargo fire?
Time is of the essence
Even if undeclared dangerous goods are the root cause of the fire-related cargo crashes experienced in recent years, investigations can take years to conclude and any resulting regulation can take even longer to implement. Chris Wren, sales and marketing director of AmSafe, a leading provider of engineered restraint systems to the aviation industry, sums up his feelings on the issue: “We just cannot afford to wait. This is a very real and present danger – and it’s only going to get worse.” And he is right. Compared to 20 years ago, aircraft are carrying far greater volumes of cargo, aircraft ranges are extended and routes more diverse. With the growth of the just-intime manufacturing concept practices, cargo is dominated by the shipment of components being flown in and out of East Asia. The flow of potentially incendiary devices, chemicals and components, declared and undeclared, cannot be stopped.
What is the solution?
“For starters,” continues Wren, “we need to accept this disturbing reality and act quickly. Undeclared dangerous goods have increased the risk of fire for air cargo. A stark reality of today’s air cargo environment is that should a fire break out in the unprotected Class E compartments on the main deck of the majority of freighter aircraft, there is little if anything to stop it from spreading quickly throughout the cargo hold and endangering the entire aircraft. In the event of such a fire, the only way to save the aircraft would be to depressurize at altitude and land as soon as possible. Of course that is not always possible if an aircraft is over water. It is critical therefore that this issue is given priority. The industry needs to be fully aware of the dangers of undeclared dangerous goods so that appropriate and swift action is taken – not sometime in the future, but now.” While Wren agrees that appropriate training and education can help to address this problem, he also believes that the industry is running out of time. Following the Boeing 747 freighter airplane accident on 3 September, 2010, at Dubai International Airport in the United Arab Emirates, the Federal Aviation Administration, Transport Canada, and the United Kingdom Civil Aviation Authority initiated a study to assess the magnitude of the potential threat to freighter airplanes from onboard cargo fires. The report made for sober reading revealing that over the period 2011 – 2020 the predicted average number of cargo fire accidents would be in excess of six per year. An additional challenge with training and education, Wren believes, lies in the scale necessary to address the problem. “You could say that there are potentially 58 million shippers in the UK alone who could be sending products all over the world. How on earth do you reach them all? And even with the best will in the world, education is not going to stop someone who wilfully ignores the regulations. “Unfortunately there are plenty of people willing and ready to ship restricted products illegally via mail or express operators. So while I applaud any action that raises awareness of this worrying phenomenon, particularly the work undertaken by the UK’s Civil Aviation Authority (CAA) in developing online, video and other high profile publicity around the issue, our fear is that we could all be fighting an uphill struggle in getting the public’s attention.” Getting their attention is one matter. It is altogether another to change behaviours. Consider this: Royal Mail in the UK found 22,000 articles of prohibited dangerous goods in one month at one sort centre. As mail is widely moved by air on both passenger and cargo aircraft, almost always in anonymous mail bags or sealed unit load devices, the detection of every dangerous product is nearly an impossible task.
Aircraft safety/integrity crucial
This is why AmSafe firmly believes that the most effective and efficient method to address this risk is to ensure that in the event of a fire, the safety and integrity of the aircraft is prioritised. As FedEx ably demonstrated with the development of their pioneering main deck fire suppression system in 2009, catastrophic events can promote positive action and viable solutions. This system is the industry’s first onboard automatic fire-suppression system and is designed to provide heightened levels of safety during international over-water flights. The highly sophisticated fire suppression system features a network of infrared thermal sensors, foamingagent generators and an overhead cargo-container injector that can control and extinguish a fire in a container in minutes. Fire blankets are also used to protect palletised loads. Current FAA regulations require that aircraft depressurise, divert to the closest airport and land immediately after any in-flight fire situation. This means that the flight crew has about 30 minutes to safely land the aircraft. With the new FedEx safety system, aircraft on lengthy international flights, which can be up to three hours from land, are able to safely divert and land. “Our new in-flight system has pushed the industry safety standard to a new level,” says Joel Murdock, managing director, Strategic Projects, FedEx Express. “With the FedEx technology our pilots have more time to review and assess an in-air situation, further ensuring their safety, and the safety of their plane and cargo.” In addition to the automatic system used by FedEx, there is also a range of passive safety solutions that can help mitigate risk by keeping a fire isolated from other cargo being transported on an aircraft. In fact in response to the problem of shipping undeclared dangerous goods, this year AmSafe launched its own fabric-based fire containment cover that is capable of withstanding temperatures over 1500°F (815°C) for longer than four hours. This combination of net and fabric cover provides a two-way barrier that effectively isolates each cargo position and prevents a fire from spreading and escalating. The four hours suppression that the active and passive systems are looking to provide will give pilots a real chance of getting the plane safely on the ground without loss of aircraft or worse. Other positive news is that AmSafe is working with certifying authorities on the development of international aerospace standards for design, performance and testing of fire containment covers. These standards will form the basis of a future FAA TSO. So while the rise of undeclared dangerous goods is indeed a most frightening prospect, it has put safety high on many agendas. In some circles, safety is even considered more serious than security issues. What’s more, there are solutions out there in the market place, and now is the time to act. Because if we don’t, then we really are ‘playing with fire.’
