Lithium Batteries and a Jerrycan at the Check-In Desk
At Abuja (DNAA) you are the commander of a commercial flight to Lagos. During boarding the ground handling agent asks you to 'just sign it off' for a passenger travelling with three items: (1) a 268 Wh lithium-ion power bank in his carry-on bag, loose with no protective case; (2) two spare 99 Wh lithium-ion laptop batteries packed inside his checked suitcase, unlabelled and wrapped in clothing; and (3) a five-litre plastic jerrycan of petrol in his checked hold baggage, which he says is for a small generator at his destination. The loadsheet has already been issued and 41 passengers are on board. There is no dangerous goods load on the manifest and no notification to the commander for any dangerous goods. The agent says the aircraft will miss its slot if the bag is offloaded.
1. For the lithium batteries, what is permitted and what is not, and why is the location of the item decisive?
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Lithium batteries are governed by the dangerous goods technical instructions, which set limits by watt-hour rating and by location, because a battery fire in the cargo hold cannot be fought effectively whereas one in the cabin can be seen and controlled.
Item 1 - the 268 Wh power bank. Lithium-ion cells above 160 Wh are forbidden in passenger baggage. A 268 Wh power bank is outside every passenger allowance and cannot be carried in cabin or checked baggage, with or without approval. It is refused. Separately, a spare in a bag must be protected against short circuit - an unmodified power bank loose in a bag is a hazard even when within the limit.
Item 2 - the 99 Wh spares. These are within the 100 Wh threshold and may be carried, but only in the cabin, not in checked baggage, and only if each is protected against short circuit - original packaging, insulated terminals, or a plastic bag per battery. As packed in the suitcase, they are not compliant.
The decision point is therefore not the chemistry or even the size alone; it is the rating combined with the location and protection. Approval from the commander does not exist as a legal concept for a 268 Wh article.
2. How do you deal with the petrol, and what is the legal basis for refusing it?
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The petrol cannot travel. It is a flammable liquid, and flammable liquids are forbidden in passenger checked and cabin baggage except in the narrow quantities the technical instructions allow for specified items, such as small quantities of alcoholic beverages or a limited quantity of certain toiletry or medical articles. Five litres of petrol for a generator is none of those; it is undeclared dangerous goods.
The legal basis is layered:
- Annex 18 and the technical instructions require States and operators to prevent undeclared dangerous goods from entering the aircraft. The operator, not the passenger, is responsible.
- The operator's approved dangerous goods programme must provide for acceptance checks, passenger information at check-in and boarding and, where carried, notification to the commander.
- The commander's duty is to ensure that what is loaded is what has been accepted and declared. If the baggage is already on board, it must be offloaded and identified before departure; the aircraft cannot depart until the item is removed.
Practically: refuse the item, inform the passenger of the reason, arrange for the container to be handed to the airport authority or returned, and record the refusal. Do not put five litres of petrol into an airport bin or a vehicle boot as a favour.
3. What is the commander's responsibility for the notification to the commander and for reporting once the items are found?
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Before departure. When dangerous goods are carried, the operator must give the commander written notification - commonly a notification to commander form - specifying the goods, quantity, location on the aircraft and, for radioactive material, the category. Here there is no such notification, and none is possible for these items because they are forbidden. The absence of a notification is itself a red flag: it means either the goods were never declared or the acceptance process failed. Either way the commander cannot sign an aircraft as ready when undeclared dangerous goods may be on board.
After discovery. Undeclared or misdeclared dangerous goods, and dangerous goods incidents, must be reported by the operator to the appropriate authority. The technical instructions require written notification of a dangerous goods incident, including undeclared goods found in baggage, to the authority, normally within 72 hours of the event, with the details of the goods, the flight and the circumstances. The occurrence also belongs in the operator's safety reporting system.
Your role as commander is not to complete the corporate report but to ensure it is triggered: record what was found, when, where and by whom, offload the items, do not allow the flight to depart until resolved, and confirm the report has been filed. Missing a slot is a commercial inconvenience; a lithium fire in the hold is not.