E-bike ‘dangerous goods’
As an avid reader of Pilot magazine (and a rider of an e-bike), I’m afraid I am the bearer of bad news regarding the Gocycle GS, reviewed in the April 2019 edition. As a ‘portable electronic device’, requirements specified by ICAO, which are given the force of law by UK and EU legislation, restrict lithium batteries contained within such a device to 100 Watt hours (Wh). According to their website, Gocycles are powered by lithium batteries in excess of 300Wh. Consequently, carriage of a Gocycle by a passenger or crew member on an aircraft (commercial or GA) would be in breach of the requirements.
The ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air contains provisions for the carriage of dangerous goods in both passenger/crew baggage, and as cargo. Except for a very specific list of items, dangerous goods are not permitted for carriage by passengers or crew. If you Google ‘IATA Table 2.3A’, you will see the list of permitted items. The passenger and crew provisions make no general allowance for battery powered devices or vehicles with a battery of more than 100Wh. It is possible for a battery up to 160Wh to be carried but this is subject to the approval of the operator. Larger batteries than this are permitted when contained in a mobility aid but such aids must be for use by passengers whose mobility is restricted by either a disability, their health or age, or a temporary mobility problem such as a broken leg.
It may well be that the battery on board the aircraft is bigger than 100Wh, but dangerous goods required on an aircraft for operational or airworthiness reasons are not subject to the requirements of the Technical Instructions.
Formula E cars and many other dangerous goods are indeed carried as cargo, but the provisions for cargo are quite different to those for passengers and crew. For example, dangerous goods carried as cargo must be prepared for transport (and subsequently handled) by trained personnel; they must be packed according to specific instructions; they must be accompanied by a document detailing the goods, with a declaration signed by the shipper to confirm that all requirements have been met (including in the case of batteries that they have met stringent test requirements prescribed by the United Nations); they are subject to a thorough acceptance check by the operator and further checks prior to loading and after unloading; segregation rules are applied during loading to ensure that, for example, flammable dangerous goods are not loaded adjacent to oxidising materials; and information about dangerous goods in cargo are provided in writing to the pilot in command so that in the event of an inflight emergency the pilot would be able to notify air traffic control accordingly. You may also wish to Google ‘Valujet 592’, where a passenger aircraft was lost with all 110 people on board due to the improper carriage of dangerous goods; sadly this isn’t the only fatal aviation accident to have been so caused.
I am bringing this matter to your attention because someone acting on the information contained in your review of the Gocycle e-bike may inadvertently break the law. If flying commercially this could also result in the inconvenience of having to leave the bike at the point of departure or, worse, not being able to return with it.
Geoff Leach, Director, The Dangerous Goods Office Ltd
While Pilot understands that the travelling public and commercial aircrew should of course be protected from undue hazard, we do not believe that ICAO’S Technical Instructions were aimed at GA. We put this to Geoff Leach, who replied:
‘I have confirmed with the CAA that the situation remains as per my original email. As a former Chairman of the ICAO Dangerous Goods Panel I can tell you you are correct in your assumption that GA is not considered in producing the Technical Instructions, the focus being on international commercial aviation. For interest, the situation is different in the USA where the regulations for the carriage of dangerous goods (hazardous materials as the Americans call them) only applies to those “in commerce” and so a PPL holder in the US could carry e-bikes.’
So it seems that, unless the CAA and Department for Transport act, while we Brits can take an e-bike over to the airfield in our car, we cannot legally load it on board our aircraft for use at destination. Ludicrous might be one word to describe this predicament – Ed.