What does the ULD fire in Hong Kong highlight?

On Sunday, 11APR21, a video showing a burning pallet on the apron at Chek Lap Kok airport (HKG - Hong Kong), spread even more quickly across social media than the fire itself. The ULD contained a shipment of Y20 mobile phones produced by the Chinese smartphone manufacturer, VIVO, and for almost everyone, the stereotype cause was clear: Lithium batteries were the obvious problem. Was that really the case? CFG spoke to Paul Horner, Managing Director of Dangerous Goods Safety Group UK, and James Wyatt, General Manager of aeroconcept, both of whom have decades of experience with DGR in a number of functions – not least IATA and training.

The facts are that the VIVO smartphones shipment was destined for Bangkok when it combusted on the apron, just before it was due to be loaded into the A330F Hong Kong Air Cargo flight RH331. It burst into flames and spread to two nearby ULDs before the Hong Kong airport fire brigade could contain it. The incident led to an immediate embargo on VIVO as well as on the two freight forwarders involved: CargoLink Logistics HK and Sky Pacific Logistics HK, Quickly, a number of carriers such as Lufthansa Cargo, Cathay Pacific, IAG Cargo, SpiceJet, Garuda and GoAir, also blacklisted VIVO.

What happened?
“We don’t know what happened, we don’t know the cause and it would be wrong to make assumptions,” Paul Horner stressed, pointing out that the shipment had made it to the airport without incident, so something had happened to cause a fire from the time it was offloaded from the truck to when it arrived on the tarmac. Yes, this was a shipment containing Lithium batteries, however, these were new mobile phones in protective outer packaging, and therefore highly unlikely to spontaneously burst into flames. “We know that most events with Lithium batteries, when they are contained in equipment, will happen either when you’re charging the device, or when you are using the device. In a retail box, a brand-new phone that has not been used before, does not just spontaneously combust. Something has happened. Whether it has been crushed, mishandled by a forklift truck, or even when it was secured on the ULD – perhaps the straps were overtightened? . There are so many things we just don’t know!”

It could have happened in mid-air.
James Wyatt agreed: “It is important not to speculate. Because of the incident, the location, the origin, and mobile phones, industry tends to automatically assume that there is an issue with Lithium batteries, but exactly what the issue is, and who is at fault, we would be wrong to speculate. However, it fits in within a series of incidents in the right place in the world, which would suggest that there was a problem either with the quality of the batteries, or the way in which they have been handled by the shipper, or by the handling agent during build-up. We don’t know what temperatures they were handled in, or how long they have been stored for, where they have been stored… There are so many questions, but the reality is, this ULD was 60 minutes from being in an aircraft – that’s the alarming thing!” Alarming too, because in this case, since the Lithium batteries were contained in equipment, they could easily have been destined to fly on a passenger aircraft. “Although we should not look at the risk being reduced if these shipments are carried on cargo aircraft. No matter the number of souls onboard, it is a potential loss of life. Cargo pilots also have families they want to go home to, after safely landing their aircraft.”

Firefighting with embargoes? The right approach?
Paul Horner is clear: “I think it is wrong that the handling agent and the phone company at this point have been embargoed. I don’t think it is the right approach, because in aviation, we operate in a no blame culture: we investigate, we learn, we find out the root cause of the incident, and then we put mitigation measures in place. By putting these penalties on organizations, it can almost drive things underground and potentially make the situation worse.” In fact, these incidents are often kept out of the public eye as far as possible, and the lack of awareness is detrimental to improving the situation. “And one of the challenges we have, is that we see the incident, the videos, and the images, but we tend not to get the post-accident investigation.” The investigation results are usually published one to two years later, but not publicly. What tends to happen, is that those shippers who do adhere to regulations and do not have incidents, get penalized. “If you do everything right, Lithium batteries and equipment that contains batteries can be moved quite safely, like any other DGR. It is just unfortunate that there are a lot of other issues we have, like counterfeit, the second-hand market, e-commerce.”

e-commerce are accidents waiting to happen
“e-commerce has opened up the market to people selling from their living rooms, and there is no control on that.” Horner last year tested processes by buying a number of DGR-related items via larger e-commerce sites and they all arrived at his home. He explains the problem: “The process is so complex, the PayPal account was in Israel, the shipper was in Malaysia. It was shipped from HKG. It got delivered by a UK domestic carrier. When I ripped off the UK label, there was a China Post label underneath, and I tracked that, and it had flown on an aircraft. And when you look at something that cost USD 15, the governments don’t prosecute because the supply chain is too complicated. Who do you prosecute? The PayPal account? The seller? The shipper? And if it is shipped from China to HKG, it has not travelled by air, so does not breach any regulations. And HKG authorities don’t have jurisdiction in China, and the shippers know all this, so they’re almost playing the system. There is a lot of organized crime linked to this, as well.” Wyatt concurs, and points out that “the probability of an incident has been magnified in the last 12-15 months, based on the huge rise in e-commerce and the shift from B2B to B2C. The demand and the volumes have increased, and the origin is generally in South East Asia, so the goods are usually being flown.” Who is to say what is in a mailed parcel?

Known and Unknown Dangerous Goods
Horner outlines that “ICAO, within Annex 19, have put a requirement on operators to do a safety-risk assessment for the carriage of cargo, including Lithium batteries, and there is now an expectation that the operators know the supply chain, where the batteries are coming from, and their quality. To be honest, that is almost impossible. The supply chains are so complex now, and I think the regulators underestimate how complicated it is. I believe it will drive a lot of carriers to decide that they won’t carry Lithium batteries, at least that they know about.” The VIVO shipment was a properly declared shipment and therefore known DGR. The majority of e-commerce shipments are likely undeclared. In both instances, however, Wyatt stresses that by the time the shipment arrives at the airport, “then this is potentially too late, because you can’t expect the last line of defence – which is ultimately the airport, warehouse, and handling staff, to pick up these issues, whether through warehouse staff, security screening, customs. The problem has to be mitigated at the start of the chain, and that is with the shipper.”

Awareness and government action needed
Alarmingly, Paul Horner, who is a DGSA (Dangerous Goods Safety Advisor) for a variety of clients such as in the automotive or e-scooter business, states that “Lithium batteries is the biggest part of our job, and a lot of customers whom we work with, tend not to realize that there are regulations until something goes wrong, or when they want to ship with a courier company which then asks if they have any training.” A distinct lack of awareness at the shipper’s end that needs fixing, and he urges governments to implement third party verification of quality standards. “There needs to be traceability! You can trace paracetamols that cost USD 1 right back to the batch number. If you can do it for a cheap medical product, why can’t you do it for Lithium batteries? There is definitely a gap there. From an operator’s point of view, rather than the DG acceptance check being based on trust as it is today, because you only see the paperwork with the box and its labels, but not what is inside; if it had some sort of external verification scheme, then we could move to a more evidence-based approach.”

Given that the number of products using Lithium batteries is constantly increasing, and the chemical set-ups behind those batteries are developing, much more needs to be done more quickly to ensure quality products, to raise awareness of regulations, and to quash counterfeit and shipping loopholes. That said, we will not know until the investigation results are published, as to how the HKG fire started, and whether the batteries were even to blame in this case.

Brigitte Gledhill

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