|
The concept of Lithium
Battery Certification for Air Transport (Li-CAT) was based on the Compliance and Awareness
Information Paper No. 6 (DGP-WG/LB/2-IP/6) issued by International Civil
Aviation Organization (ICAO) Dangerous Goods Panel Working Group on
Lithium Batteries 2014. It is encouraged to establish a greater level of
voluntary compliance on lithium batteries air transport. An effective means
was to push compliance back down the entire supply chain towards the
manufacturer. Thus establishing a trust-based certification along the lithium
battery supply chain is essential. Lithium battery is an
inevitable component in a wide range of consumer electronics, from mobile
phones to electric vehicles. Hong Kong has long been an entrepot for trade
with the Mainland and is the key conduit for international trade with China.
With Guangdong being a major production base of lithium batteries, Hong Kong
has to endure an enormous amount of lithium batteries export, especially by
air. With the potential of poor
production quality and counterfeit issue in electronics manufacturing, this
poses potential threat to aviation safety. In addition, the supply chain
model, between Hong Kong and China for international export, makes the
threats less identifiable by the presence of conflict of interest between
supply chain entities, multi-layered consolidation, etc. Current Situation under existing programmes: Because of the huge, worldwide
demands for lithium batteries, billions of them are shipped annually in air
cargo on both passenger and cargo aircraft. Volumes are expected to increase
substantially, with batteries becoming more compact and even higher energy
density. Lithium batteries have become such a common, everyday item that they
have been taken for granted by consumers. Little thoughts have given to the
precautions that are essential to ensure lithium batteries aviation safety in
air transport. Experience has shown that there are shippers and freight forwarders
who, either deliberately or through ignorance, do not follow the
requirements. Consequently, incidents involving lithium batteries on board
aircraft have occurred. According to the
Dangerous Goods Air Transport Statistics Report 2013, the lithium batteries
air transport statistics are shown below:
From the statistics shown,
lithium battery contributes to an exceptionally high proportion of total
dangerous goods transported by air in terms of tonnage. But these figures
only take into account lithium batteries that are properly declared to the
operators. They cannot account for “undeclared” shipments, the exact volume
of which is unknown, but from the incidents that have occurred, “undeclared”
shipments are clearly widespread. Being most common dangerous goods
transported, the safety and security of air transport of lithium battery have
to be maintained and monitored closely and comprehensively. Under RAR, known
consignors/account consignors are recognized by freight forwarders based on
their own reviews. These reviews may be subjected to bias from potential
profits by the forwarders and thus may not reflect the actual standard of the
shippers. This model is in a conflict of interest situation for the
forwarders and the shippers. Also, multi-layered
consolidation is a very common practice in the industries in Hong Kong. This
poses another potential threat to the lithium batteries shipment since
misdeclaration at any part of the layer will affect the rest of the chain.
The multi-layered consolidation makes the misdeclaration untraceable and
undetectable. In such situation, third-party
validations should be involved to assess the standard and compliance of the
shippers and forwarders in Hong Kong. By certifying qualified shippers and forwarders,
a trust-based supply chain model can be established in a progressive
manner. Introducing a New Regulatory
Programme Currently,
lithium battery handling supply chain entities in Hong Kong are not regulated
in a way commensurate with their comprehensiveness of services and level of
operational risk involved. Instead of being regulated by a single
comprehensive compliance, they are subject to scattered regulatory programme
for various specific aspects. With
the advancement in technology and rapid changes in manufacturing process,
high-risk lithium batteries once confined to high-end factories are
increasingly manufactured in amateur settings. This leads to an enormous
quantity of low quality lithium batteries, which poses great threat to the
aviation safety once boarded on aircrafts. It can be seen that from the
manufacturing to the transport of lithium battery, different entities are
involved. Each entity (Manufacturer, Shipper, Forwarder, and Airline) should have
their own sets of regulatory measures to ensure the aviation safety of
lithium battery shipments. There
are calls to tighten up regulatory oversight through corporate governance,
facilities-based and procedural-based regulations in line with international
common practices. The need for such a change is made ever more urgent and
necessary following aforesaid aviation incidents resulting from high-risk
lithium battery shipments. According
to Compliance and Awareness Information Paper No. 6 (DGP-WG/LB/2-IP/6) issued
by International Civil Aviation Organization (ICAO) Dangerous Goods Panel
Working Group on Lithium Batteries 2014, it is encouraged to establish a
greater level of voluntary compliance on lithium batteries air transport. An
effective means was to push compliance back down the entire supply chain
towards the manufacturer. Thus establishing a trust-based certification along
the lithium battery supply chain is essential. In
the light of the above, there is a genuine need to introduce a robust and
comprehensive regulatory programme for the supply chain. In view of the
findings and recommendations of the aforementioned reviews, we consider that
effort should be focused on introducing a new regulatory programme covering
various stakeholders in the international lithium battery supply chain. |
