Incorporating them in to Class 9, I believe takes away from the hazard which they truly post. I remember back in the 1990s when the military used to move these, how dangerous they were and how they were forbidden in air transportation at any time, but flew with a number of Special Permits following them around. It was a pain!
We continue to debate these things, slap band-aids on the existing rules, to the point that the lay-person has no idea what they are doing any more and are terrified to accept or load them, yet we run around with two or three of them on our person at any given time. The Packing instructions with their subsections and limits are changing every year and becoming even more complicated for both the shipper and acceptance person to comprehend. This may lead to clandestine shipments of undocumented packaged just to get around the fact that the rules are becoming a nuisance.
Of all the DG that I experience, these need to be the most straightforward and simple to understand so that there is no question and that compliance is easy for all concerned. So that acceptance is achieved without difficulty and so that it does not promote the practice of clandestine shipping. To make things worse, the differences between US and ICAO regulations complicates the matter to the point, where it can become confusing even to "experts".
Screw it....just ship everything as fully regulated. I've hear that exclaimed before.
The rules for Lithium batteries need to be completely overhauled. They need to be classified in their own Class / Division and the Packing Instructions need to be easy to read and understand so that there are no questions as to how to comply.
Im am not certain as to the politics concerned with why this has not been done. I understand that it has been brought up in the past and often shot down. I sit and read the continuing debate by the ICAO DGO to ban these items all together and the differenced that the IATA DGB have with the ICAO proposal. The fact the the US FAA has yet to Harmonize completely with the International regs and that the proposals all seem to continue the cycle of making the existing rules much more complicated.
What do you think?
