PRBA Assails Fundamental Flaws in FAA Safety Study on Air Shipments of Lithium Batteries
The Portable Rechargeable Battery Association (PRBA) said a recent Federal Aviation Administration (FAA) study on the potential risks posed by the air transport of lithium batteries was based on flawed assumptions, unsound methodology and faulty data.
"Unfortunately, the FAA study has provoked unwarranted scare-mongering in the news media and distracted attention from important safety issues. Everyone agrees improperly packaged lithium batteries should not be shipped as cargo. This safety goal can best be achieved by rigorous enforcement that will ensure compliance with existing international battery transportation regulations," PRBA Executive Director George A. Kerchner said.
In a letter to the Secretary of the International Civil Aviation Organization’s Dangerous Goods Panel, PRBA detailed its concerns about the methodological mistakes in the FAA study.
– The FAA based its study on five aircraft incidents. In two of the five incidents, batteries were onboard the aircraft. The FAA study assumed these batteries contributed to the two incidents, then developed its risk model from this assumption. "But no facts are presented that indicate any involvement of batteries in the incidents," PRBA’s letter noted. "The presence of batteries onboard certainly is not enough to justify this assumption and should not be the basis for FAA’s next study on the cost benefit ratios for various mitigation strategies."
– The FAA assumed bulk shipments of lithium batteries likely contributed to two incidents involving air cargo planes. "This assumption is unfounded," PRBA’s letter said. In one incident, the National Transportation Safety Board did not identify bulk shipments of lithium ion or lithium metal batteries onboard the aircraft. An investigation into the recent incident in Dubai never said bulk shipments were "likely contributors" to the accident.
– The FAA claimed air shipments containing batteries pose a more significant risk than those without batteries. "However, in fact, there is no statistically significant difference between the ’battery-related’ and ’non-battery-related’ incident rates," PRBA’s letter said, and explained why. In fact, the risks of an incident may be higher for air cargo shipments that do not include batteries, the letter noted.
– The FAA failed to distinguish between the very different shipping practices for lithium ion and lithium metal batteries, and then incorrectly stated that 50 percent of both are shipped on U.S. all-cargo airlines for an average of 2,116 miles. "This is not true," the letter said, because the bulk of lithium metal batteries are transported by ships and trucks. Most lithium ion batteries are in consumer electronic products or shipped with laptops, mobile phones and other electronic goods. As a result, the FAA is "greatly overstating the risk," the letter said.
"PRBA has expressed serious doubts about efficacy of the FAA study because it seems to have either misunderstood or misused data on the basis of faulty premises. It is not a study on which any policy changes could reasonably be based," Kerchner said.