Assessing the Risk of Lithium Batteries - Bob Richard

Slide 1: 

- 1 - Assessing the Risk of Lithium Batteries A Presentation by Bob Richard, Vice President of Government Affairs Labelmaster Services Presented September 2009 at the 2009 Dangerous Goods Instructor’s Symposium

Lithium Battery Update : 

- 2 - Bob Richard Deputy Associate Administrator Office of Hazardous Materials Safety Pipeline and Hazardous Materials Safety Administration (PHMSA) US Department of Transportation Lithium Battery Update

Why are we concerned? : 

- 3 - Why are we concerned?

February 2008, a flashlight fire onboard Northwest Airlines flight from Tokyo to Hong Kong : 

- 4 - February 2008, a flashlight fire onboard Northwest Airlines flight from Tokyo to Hong Kong

July 2008, UPS Freight trailer fire occurred on Route I-94 in Jackson MI. : 

- 5 - July 2008, UPS Freight trailer fire occurred on Route I-94 in Jackson MI.

Slide 6: 

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Reported Battery Incidents(Since January 1, 1971) : 

- 7 - Reported Battery Incidents(Since January 1, 1971)

Recently Reported Battery Incidents(January 1, 2008 - August 20, 2009) : 

- 8 - Recently Reported Battery Incidents(January 1, 2008 - August 20, 2009)

Recently Reported Battery Incidents(January 1, 2008 - August 20, 2009) : 

- 9 - Recently Reported Battery Incidents(January 1, 2008 - August 20, 2009)

Lithium and Other Batteries OHME Activities : 

- 10 - Lithium and Other Batteries OHME Activities In January 2007, PHMSA established and executed a nationwide investigation team that focuses on lithium battery transportation safety. The team's focus has also expanded to include the rising issues and incidents involving many other electric storage devices (having high stored energy / heat generation risks).

PHMSA Lithium Battery Team Members : 

- 11 - PHMSA Lithium Battery Team Members Eastern, Chris Michalski (609) 989-2256 Central, Terry Pollard (847) 294-8580 Southern, Bill Stevens (404) 832-1140 Western, Mike Khayata (909) 937-3279 Southwest, Tom Lynch (713) 272-2820 HQ, Dan Derwey (909) 239-5140

Since March 15, 2007, PHMSA has conducted almost 300 battery related inspection activities. : 

- 12 - Since March 15, 2007, PHMSA has conducted almost 300 battery related inspection activities. Many of these activities were in response to battery complaints and reported incidents. The inspection activities included 25 battery manufacturer inspections, three of which were joint inspections with the FAA. In total, there were eight joint inspection activities involving PHMSA and FAA.

Joint Investigations : 

- 13 - Joint Investigations

Complaint Investigations : 

- 14 - Complaint Investigations

In April 2008, PHMSA investigated a UPS truck fire incident on the Pennsylvania Turnpike involving batteries sent for recycling. : 

- 15 - In April 2008, PHMSA investigated a UPS truck fire incident on the Pennsylvania Turnpike involving batteries sent for recycling.

Results of the PHMSA’s Investigations into the Batteries Recycling Program : 

- 16 - Results of the PHMSA’s Investigations into the Batteries Recycling Program

Slide 17: 

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Slide 18: 

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April 2009, PHMSA issued the battery enforcement letter in reference to shipments of spent batteries. : 

- 19 - April 2009, PHMSA issued the battery enforcement letter in reference to shipments of spent batteries.

In April 2009, Industry submitted results of experiments with alkaline batteries, requesting interpretation regarding the requirements to ship such batteries. : 

- 20 - In April 2009, Industry submitted results of experiments with alkaline batteries, requesting interpretation regarding the requirements to ship such batteries.

Recent Developments - Letter from ALPA : 

- 21 - Recent Developments - Letter from ALPA

Slide 22: 

- 22 - June 18, Honolulu, HI, a burned package was discovered inside a Unit Load Device.

Slide 23: 

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Slide 24: 

- 24 - July 15, 2009, Santo Domingo, Dominican Republic One of several packages transported from Romulus, MI was emitting smoke and smoldering. The package was found to contain loose lithium-ion cell phone batteries with no terminal protection. The documentation listed the contents as used batteries – non-hazmat.

Slide 25: 

- 25 - August 14, 2009, Minneapolis-St. Paul Airport

Slide 26: 

- 26 - Additional Photos

Additional Incidents : 

- 27 - Additional Incidents August 13, 2009 – Package “Warm to the Touch” upon handling in Louisville, KY (prior to loading on a flight to Manchester, NH)

Additional Incidents : 

- 28 - Additional Incidents August 15, 2009 – Smoldering Packages in ULD unloaded at Taipei, Taiwan (Carried by Air Macau)

Additional Incidents : 

- 29 - Additional Incidents August 25, 2009 - lithium battery fire at Federal Express terminal in Medford, MA

Additional Incidents : 

- 30 - Additional Incidents September 10, 2009 AA Flight 25 (a 757) from Boston to LAX declared an emergency on decent after a passenger in first class attempted to hand the flight attendant a Personal Electronic Device (PED). The DVD player’s battery pack fell from the device and upon impact with the cabin floor burst into flames.  Two flight attendants tried to extinguish the fire with a haylon fire extinguisher and when the fire did not extinguish they poured water over the battery pack which extinguished the fire.  Both flight attendants were brought to the hospital for smoke inhalation.

Future Actions : 

- 31 - DOT will take all actions necessary to expedite the current rulemaking that is intended to impose more restrictive transportation requirements on lithium battery shipments. The NPRM was sent to OMB on September 10th Expected publication this Fall We have requested that the ICAO DGP hold a special working group session to address the safety risks. Future Actions

Future Actions : 

- 32 - Additionally, PHMSA and FAA propose instituting an aggressive outreach and enforcement campaign targeted at lithium battery shippers and carriers. We plan to publish a safety advisory to inform shippers and carriers of the recent lithium battery incidents and their obligations under the regulations. The safety advisory will emphasize the enforcement penalties that can be imposed for violations of the regulatory requirements and of our intention to pursue aggressive enforcement action. The agencies will publicize as broadly as possible the enforcement actions, including financial penalties imposed on specific shippers and/or carriers. Future Actions

Future Actions : 

- 33 - The minimum and maximum civil penalties for violations of the Hazardous Materials Regulations are $250 and $50,000 per violation, respectively, except that a civil penalty up to $100,000 may be assessed when the violation results in death, serious illness, or severe injury to any person or substantial destruction of property. Criminal penalties are determined under title 18 and may also include imprisonment for not more than 5 years, or both; except that the maximum amount of imprisonment shall be 10 years in any case in which the violation involves the release of a hazardous material that results in death or bodily injury to any person. Future Actions

PHMSA FOCUS : 

- 34 - PHMSA FOCUS PHMSA inspections have centered around manufacturer's, testers, shippers and recyclers. By gaining a better understanding of the entire transportation stream, cradle to grave, we intend to identify and reduce the potential for battery incidents prior to their being offered into transportation. In this process we drive down the risk by targeting the greatest threats (be it the highest hazard materials, worst performers, complaints, incidents and accidents). We will step up outreach and enforcement to target undeclared and/or non-compliant shipments

Questions? : 

- 35 - Questions? Bob Richard 1200 New Jersey Avenue, SE Building, Washington, DC 20590-0001 Phone: (202) 366-0586 E-mail: bob.richard@dot.gov