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 dangerous goods. As witnessed in 2015 with hoverboards, and again in 2016 with the Samsung Galaxy Note 7, lithium batteries and other dangerous goods (aka hazardous materials) can create real safety threats in the absence of proper regulation. Mitigating the risk to aviation safety from dangerous goods requires a focus on two specific areas: improving dangerous goods regulations and eliminating shipments of undeclared dangerous goods.

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 dangerous goods regulations for the carriage of lithium batteries as cargo onboard commercial aircraft, both passenger and cargo, continue 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. The Department of Transportation has begun the process of harmonizing these into the U.S. regulations; however, no final rule has been issued. Additionally, these new standards do not go far enough in addressing 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” dangerous goods. There are no official estimates of what percent of parcel shipments contain undisclosed dangerous goods; however, the FAA tracks incidents where hazardous materials 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 2015, the FAA received 1,129 reports of such events, and 564 of the incidents involved undeclared dangerous goods.

ALPA’s research indicates that the biggest weakness in the shipment of dangerous goods by air is the reliance on an “honor system” approach by the airlines and regulators. Increased attention to and accurate data is needed to eliminate undeclared dangerous goods shipments by air.


  • DOT should immediately harmonize U.S. Hazardous Materials Regulations to conform to the international dangerous goods technical instructions implemented by ICAO on April 1, 2016.
  • To improve the Hazardous Materials Regulations, these regulations should at a minimum:
    • Provide lithium batteries with the full range of safety protections afforded other dangerous goods transported by air; and
    • Define special packaging requirements for lithium batteries when shipped as cargo by air.
  • DOT should initiate a public awareness and education campaign outlining what materials are considered dangerous goods when shipped as cargo by air and improve hazmat training for employees who handle or ship packages.
  • DOT should require shipper verification that the package, cargo, or freight being submitted for transport does not contain dangerous goods or hazardous materials.
  • FAA and PHMSA should implement a pilot program that provides for the random screening of a small percentage of cargo packages transported by air.

Download the Lithium Battery White Paper
Download ALPA's Position Paper