E-bike ‘dan­ger­ous goods’

Pilot - - AIRMAIL -

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.

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