(Is it permissible to place Lithium batteries of Section IB and Section II in the same APIO or in the same Overpack?)

Q.
I can understand that regardless of lithium ion or lithium metal, Section IB and Section II of these lithium batteries must not be in the same APIO, but what about Overpacks? Section II of PI 965 and PI 968 both have a paragraph on Overpacks where it states Section II may be overpacked with other dangerous goods or non dangerous goods as long as they will not react dangerously. Please give us guidance. (31 Jan 13)

A.
Since there were many lithium batteries which were not shown on the NOTOC that were loaded on the aircraft as cargo without the captain knowing he had such cargo, and these may have been the cause of recent aircraft accidents, a new Section IB had been installed in PI 965 and PI 968. The main intent of the introduction of Section IB was to have the airline make an acceptance check and enter such items on the NOTOC to alert the flight crew. Shipments of Section IB were subjected to a dedicated acceptance check and were obligated to enter into the NOTOC. Shipments of Section II on the other hand do not require acceptance check nor need to show on the NOTOC.

The two sections are totally independent of each other, and therefore APIO is out of the question, neither is Overpack. Although it does state in Section II of PI 965 and PI 968 that as long as they do not react dangerously with each other, Section II can be overpacked with other dangerous goods or non dangerous goods. Thence however if so done, how can the airline make a meaningful acceptance check? Since Section IB had been introduced to enhance safety, in order to achieve the intended level of safety, it is obvious that overpacking Section IB with Section II must be discouraged.


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