Safety Risk Assessment (SRA)
Carriage of Lithium Batteries
Version 1
January, 2016
Carriage of Lithium Batteries
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Page 2 of 6
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.
Page 4 of 6
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
Page 5 of 6
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.
Page 6 of 6
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
Version 0.5
January 2016
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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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January 2016
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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
Version 0.5
January 2016
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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
Version 0.5
January 2016
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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
Version 0.5
January 2016
Page 5 of 6
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
Page 6 of 6
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
