Attachment B - UAS Risk Assessment Work Statement Final.docx

9. Other pertinent information or special considerations………………………………………………….12

Risk assessment for HAZMAT packages in an Unmanned Aircraft Systems (UAS) environment Work Statement

1. Project title Risk assessment for HAZMAT packages in a UAS environment

2. Introduction This work intends to identify potential hazards, vulnerabilities, and package faults with Unmanned Aircraft Systems (UAS) package delivery systems. Currently, sections of title 49 of the Code of Federal Regulations provide great guidance and summation of general requirements for packaging and packages for a “typical” shipper; however, UAS operators are NOT your typical shipper. Specifically, many of these new operators are experimenting with various means of package delivery systems such as: dropped via tether, delivered via parachute drop, delivered via free-fall drop, etc. Additionally, UAS packages are exposed to a myriad of weather, atmospheric, and environmental effects that need to be assessed. Because of these new variables impacting UAS shipping, many of the current standards and testing may be inadequate for UAS shipping operations. The safety goal of any packaging standard is to adequately protect the contents against shock, vibration, compression, and/or atmospheric hazards during delivery, there is a need to assess the unique shipping conditions of UAS package delivery systems. The proposal work would evaluate the safety performance of existing dangerous goods packaging requirements in an unmanned aerial systems (UAS) environment.

3. Background This effort will evaluate the safety performance of existing dangerous goods packaging requirements in an unmanned aerial systems (UAS) environment. The work will account for operational conditions specific to the carriage of dangerous goods via UAS and the corresponding hazards, the safety performance of existing packaging standards, and identify appropriate risk mitigations. It will also identify potential hazards associated with malfunctions of UAS package containment systems at various cruise altitudes, up to 400’ above ground level (AGL), which could inadvertently drop items during transit. While UAS operations may differ from manned operations in the design and implementation of the safety standards for transporting packages, the intention of adequate safety controls being applied to mitigate risk remains.

a) Package Requirements Package delivery via UAS is an emerging concept that is expected to become mainstream in the near future. Current regulations in title 49 of the Code of Federal Regulations regarding dangerous goods packaging requirements may not provide adequate risk mitigation in a UAS environment. Accordingly, this effort will evaluate the safety performance of existing packaging requirements, identify any additional necessary mitigations, and provide recommendations.

b) Drop Testing The typical cruise altitude during the en-route phase of UAS package delivery is between 200’ – 400’ above ground level (AGL). Currently, the 49 CFR requires package drop testing to be conducted at an average height of approximately 4.1 ft (depending on Packing Group). This requirement accounts for a package falling off a pallet and landing on the floor of the aircraft fuselage. During UAS package delivery operations, packages are often carried externally to the aircraft fuselage; in the event of a malfunction, the package could fall hundreds of feet to the ground. This increased risk is not currently accounted for in the existing title 49 hazardous materials regulations on package drop testing requirements. This work will evaluate the current title 49 hazardous materials regulations drop testing requirements, identify any additional necessary mitigations, and provide recommendations.

c) Leak proofness Tests During UAS package delivery operations, many operators choose to carry the package external to the aircraft fuselage. Accordingly, the package could be exposed to many additional environmental factors such as precipitation, temperature variations, and wind/airflow up to 100 MPH during cruise flight. Current title 49 hazardous materials regulations may not provide adequate risk mitigation for these additional factors. This effort will evaluate the current requirements in title 49 of the Code of Federal Regulations regarding leak proofness requirements, identify any additional necessary mitigations, and provide recommendations.

d) Damaged Vehicle Battery Interaction with Package Contents The vast majority of the UAS’s being used in package delivery rely on lithium-ion batteries (LiBs) for their on-board power. In an accident, damaged batteries carry greater potential to short-circuit, release heat, or even cause a fire. Once ignited, battery fires can be difficult to extinguish. Additionally, LiBs can go into thermal runaway- a chain reaction leading to a violent release of stored energy and flammable gas/electrolyte. Moreover, this safety concern could be exacerbated by the contents of the UAS package if it includes hazardous materials.

As an option for this work, the Contractor will evaluate risks associated with vehicle power sources (lithium-ion batteries) and their interaction with package contents. Under this option, the Contractor will provide recommendations regarding equipment, training, and package containment requirements. By providing recommendations and guidance to applicable administrations, manufacturers, and operators, the guidance will allow the growth of new technologies while ensuring the safe delivery of packages via UAS.

4. Objectives The objective of the proposed work is to conduct a comprehensive evaluation of the safety performance and regulatory compliance of existing packaging standards for transporting dangerous goods via Unmanned Aerial Systems (UAS). This effort aims to assess the adequacy of current packaging requirements, operational protocols, and risk mitigations specific to UAS delivery conditions, with a focus on identifying and addressing potential safety gaps.

5. Scope This Task Order will evaluate the safety performance of existing dangerous goods packaging requirements in a UAS environment. The effort will account for operational conditions specific to the carriage of dangerous goods via UAS and the corresponding hazards. This work will also assess the safety performance of existing packaging standards and identify appropriate risk mitigations. This effort will be conducted through the completion of the following tasks:

Task 1: Program management Task 2: UAS landscape review Task 3: Current regulatory requirements assessment Task 4: Flight condition analysis Task 5: Package drop testing and assessment Task 6: Final report Option: Thermal event analysis and testing The Contractor must furnish the necessary personnel, materials, equipment, facilities, travel, and support in accordance with this Task Order. The Contractor must provide the appropriate program management, and project control necessary to manage this Task Order; and ensure that the cost, schedule, and quality requirements are continually tracked, the status communicated to the Contracting Officer’s Representative (COR), and that this Task Order is successfully completed.

TASKS

The Contractor must perform the following Tasks during this effort:

5.1 Task 1 – Program Management

Subtask 5.1.1: Technical Kickoff Meeting:

The Contractor must hold a Technical Kickoff meeting to review sponsor needs, review the Project Task Plan, clarify any issues with scope, and discuss the technical approach and methodology. The kickoff meeting will be held within 45 days of contract award and may coincide with the initial draft Project Task Plan release for PHMSA review.

Subtask 5.1.2: Project Task Plan:

The Contractor must develop a Project Task Plan which includes the following:

1. Detailed work plan covering its approach to performing the tasks in this Task Order.

2. A project schedule to track project activities, durations, deliverables, and milestones. The project schedule must include identification and tracking of the schedule critical path(s). The contractor must maintain and update the project schedule as the work progresses, however, no less than once a month.

3. Establishment of Non-Disclosure/Data Sharing/Legal agreements for all stakeholders.

The Contractor must provide an initial draft of the Project Task Plan for PHMSA review and comment five (5) business days prior to the Technical Kickoff Meeting. The Government will provide comments/recommended changes within ten (10) business days. The contractor must adjudicate the comments provided by the PHMSA and submit a Final Project Task Plan no later than five (5) business days after Government comments are received.

Subtask 5.1.3: Progress Update Meetings:

The Contractor must hold monthly Progress Update Meetings with the COR, Program Manager, and sponsors. At each Update Meeting, the Contractor must present detailed activity status updates, review schedule progress, and documentation adjustments based on COR feedback. NLT five (5) business days after each Update Meeting, meeting notes must be provided by the Contractor to the COR until the project is completed. Slides for the meetings must be sent to the COR at least 24h in advance of the meeting.

Subtask 5.1.4: Financial and Project Status Reports:

As part of the Progress Update Meetings, the Contractor must provide Monthly Financial Reports, highlighting financial progress and any risks or areas of concern. In addition, the Contractor must develop and maintain a Monthly Project Status Report describing the project and current status. The Financial Report and the Project Status Report must be provided monthly but NLT five (5) business days after each Update Meeting.

Subtask 5.1.5: Annual Report and Presentation:

On an annual basis, the Contractor must provide an Annual Report that summarizes the previous year’s work effort under this Task Order. The Contractor must also prepare and present this information annually to PHMSA.

5.2 Task 2 – UAS landscape review

The Contractor will review all publicly available information concerning how Industry is currently performing package delivery via UAS and UAS systems both within the US and internationally. Focus areas to consider should include (but not be limited to) package certification processes; UAS operations and maintenance; emergency protocols; UAS safety measures or risk mitigation tools employed by Industry; service areas and delivery volume; in-flight or post-flight monitoring; any issues with package survivability during the cruise flight or upon delivery; and final delivery mechanism (tether, airdrop, land, and release, etc.).

The Contractor will create a review report that describes the current landscape of the UAS industry, covering at minimum the focus areas previously described as well as successes/gaps for certification and regulation. The report will provide recommendations for updated and/or new certification processes and/or regulations to ensure the safe operations of package delivery systems via UAS. The literature review report will be delivered NLT 3 months after the contract award.

5.3 Task 3 – Assess current regulatory requirements for the carriage of hazardous materials via UAS The Contractor will assess current regulatory requirements for the carriage of hazardous materials via UAS. This will include packaging requirements, drop testing requirements, and leak proofness requirements.

After the evaluation of the current title 49 regulations regarding packaging, drop testing, and leak proofness requirements is complete, the Contractor must conduct a safety risk assessment outlining findings and incorporate into the report following FAA Orders 8040.4C and 8040.6A standards. The report will rank the identified hazards and risks from least severe to most severe as well as the probability of the risk event to occur. The safety assessment and report will identify any additional necessary mitigations and requirements and provide recommendations. The safety risk assessment report will be delivered NLT 3 months after the contract award.

5.4 Task 4 – UAS Package Delivery Operations Flight Conditions Analysis UAS package delivery operations vary greatly in scope. Some packages are delivered by the UAS landing on the ground, some are lowered slowly via tether, some are physically dropped from the UAS at various altitudes, and some are dropped via parachute. The effects on packaging (impact forces, environmental exposure, vibrations, etc.) also vary greatly because of the different delivery methods. Operating cruise altitudes also vary, which may affect pressure on the package and other conditions. The Contractor must identify the flight conditions during all phases of flight to determine if existing dangerous goods requirements mitigate risk to an acceptable level.

Flight conditions effort will be conducted, considering the many different operational possibilities. The Contractor will identify any additional mitigations necessary for attaining an acceptable level of safety. The Contractor must develop a report summarizing the findings, which will identify any additional necessary mitigations and requirements, and provide recommendations. This task will also inform a test matrix for Task 5’s package drop testing. The package operations flight conditions analysis report will be delivered NLT 6 months after the contract award.

5.5 Task 5 – Assess package drops at various heights AGL, with a variety of different classes and categories of hazardous materials The typical cruise altitude during the en-route phase of UAS package delivery operations is typically 200-400’ above ground level (AGL). During the package delivery phase, the typical height varies greatly, from landing (0 feet) to over 100’ AGL. Drop testing must be done to assess package drops at various heights AGL, considering different hazard classes and categories of hazardous materials. Such items will include surrogates for a large representative sample of common dangerous goods items. Specific items will also include lithium batteries, and items containing lithium batteries such as phones, laptops, tablets, remotes, etc. Drop tests should be conducted to capture representative drop heights. At a minimum, the Contractor should test the following heights AGL: 1.25m (4.1’), 3m (10’), 50m (164’), and 121m (400’) with various airspeeds determined in Task 3. The Contractor will assess the damage to the contents of the packages dropped at the aforementioned heights. The Contractor will assess whether the packaging successfully contained the item. The Contractor will assess whether any packages that are leaking resulted in a spill or were unable to contain the enclosed liquid/item. The Contractor will evaluate current title 49 regulations regarding packaging requirements to determine any necessary additional safety mitigations and provide recommendations.

Subtask 5.5.1: Produce Test Plans and Procedures Necessary to Define and Conduct Prescribed Drop Testing:

The Contractor will determine the techniques, location, schedule, and equipment needed to conduct the subject drop testing and will carefully document the results. This analysis must be expanded into both a strategic Test Plan and a detailed Test Procedures Document. The resultant procedures will be defined in individual Test Cards for each drop test. The Contractor must provide the drop test plan and procedures for Government review (45) days prior to the test event. The Contractor will adjudicate comments and gain approval before testing can proceed.

Subtask 5.5.2: Acquire/Produce Test Objects, Instrumentation, and Infrastructure to Be Used in Drop Testing:

The Contractor will acquire the objects to be subjected to drop testing in sufficient numbers and of adequate variety to complete the entire sequence of prescribed drop tests. They must also acquire or produce any needed instrumentation and equipment required to commence testing.

Subtask 5.5.3: Drop Testing:

The Contractor will conduct the drop tests in compliance with the approved Test Plan and Test Procedures on each prescribed category of packages: liquids, solids, gasses, and lithium-ion batteries in laptops, phones, and remotes. Drops must be conducted from multiple heights in compliance with the test plan. The number of repetitions shall be adequate to constitute a statistically significant result. The testing will be completed according to the proposed schedule supporting the delivery of the drop testing report.

Subtask 5.5.4: Drop Testing Report:

The contractor will develop a report summarizing drop test findings. They will identify any additional necessary mitigations and requirements, provide recommendations, and deliver the resulting report summarizing the findings and recommendations. The report will be delivered NLT 12 months after the contract award.

5.6 Task 6 – Final Report

The Contractor will summarize and aggregate all of the previous papers and reports (excluding meeting notes) into a final report package for the overall effort based on comments received from the sponsor on the previous reports. The report must include an executive summary that captures the context, project overview, and key findings of the work. The report must capture the safety risk management process, which will include mitigation strategies, residual risk estimates, safety performance monitoring strategies, and recommendations for future activities that are identified during the effort. The report should also discuss how research outcomes will inform industry standards and regulations. The report will be delivered NLT 21 months after the contract award.

5.7 Task 7 – Project One-Pager

The Contractor will deliver a project one-pager for PHMSA to use to carry out outreach and engagement. This one-pager should target non-technical audiences. The project one-pager should include:

· 508-compliant visuals (e.g., figures, graphs, pictures) that serve an explanatory purpose for the project

· Concise textual information that covers the context, project goals and objectives, and anticipated impact The project one-pager must be delivered NLT 10 months after the contract award. The project one-pager must be designed to allow printing on a standard 8.5”-11” piece of paper.

Option – Thermal Event Assessment of the Aircraft Battery This option will assess the probability of occurrence of a thermal event (aircraft battery) caused by an accident or battery short-circuit and how the event can interact with the contents of the package and/or delivery system. Crash Testing should be utilized to reach a determination. The test should assess the probability of a battery igniting (thermal event) and the risk this would pose to the package/cargo contents. This test should be conducted through the actual “crashing” of a UAS in order to assess the entire event. Testing will also incorporate the carriage of a representative variety of hazardous materials (or their surrogates), with flammable liquids and LiBs being the most common. Additionally, testing will be conducted at various heights AGL.

Subtask O.1.1: Produce Test Plans and Procedures:

The Contractor will develop test plans and procedures necessary to complete the thermal event testing based on the findings from Tasks 1, 2, and 3. The contractor must provide test plans and procedures for Government review (45) days before the test event. The contractor will adjudicate comments and gain approval before testing can proceed.

Subtask O.1.2: Develop sUAS Battery Launcher and Attachment Details:

The contractor will translate the testing requirements and the details of testing described in the Test Plan and Test Procedure into the specific hardware required to conduct the crash testing.

Subtask O.1.3: Assessment of Battery Vulnerability through Crash Testing:

The contractor will assess the probability of a battery thermal runaway due to impact (different types of batteries, impact conditions, and state of charge will be investigated.) They will also assess the safety risk of a battery thermal runaway interacting with package contents using representative hazardous materials (or surrogates) and LiBs. This subtask will be completed through physical testing. The testing will be completed according to the proposed schedule supporting the delivery of the thermal event testing report.

Subtask O.1.4: Thermal Event Assessment Report:

The Contractor will develop a report summarizing accident findings about the UAS’ power source and the interaction of the package contents, which will identify any additional necessary mitigations and requirements, and provide recommendations. The report will be delivered NLT 18 months after the award of the option.

6. Place of performance and Period of Performance The above contracted work shall be performance at the location of the contractor and period of performance shall be date of award through +24 months.

7. Deliverables/delivery schedule

NLT 5

Business Days after the Date of the Technical Kickoff Meeting

5.1.2

Project Task Plan

The contractor must provide an initial draft of the Project Task Plan for FAA review and comment five (5) business days prior to the Technical Kickoff Meeting. The Government will provide comments/recommended changes within ten (10) business days. The contractor must adjudicate the comments provided by the FAA and submit a Final Project Task Plan no later than five (5) business days after Government comments are received.

*Updates to the project schedule are due as work progresses, but no less than once per month.

Date of Award

(T) + 1 Month

5.1.3

Technical Interchange Meeting (TIM) Presentation and TIM Meeting Minutes

TIM Meeting and Presentation: Date of Award

(T) + 1 and monthly Thereafter

TIM Meeting Minutes: NLT five (5) business days after each TIM

5.1.3

Monthly Financial Reports

NLT five (5) business days prior to scheduled TIMs

5.1.4

Monthly Project Status Report

NLT five (5) business days prior to scheduled TIMs

5.1.5

Annual Report and Presentation

Date of Award (T) + 12 Months and annually thereafter

5.2

Literature Review Report

Microsoft Word document

Sign off from

COR

Date of Award

(T) + 3 Months

5.3

Safety Assessment Report

Sign off from

COR

Date of Award

(T) + 3 Months

5.4

Flight Conditions Report

Sign off from COR

(T) + 6 Months

5.5.1

Drop Test Plans and Procedures

Microsoft Word document

Sign off from COR

45 days prior to the test even

5.5.4

Drop Test Report

(T) + 12 Months

5.7

Final Report

Microsoft Word document and pdf

Sign off from COR

(T) + 21 Months

O.1.1

Thermal Event Test Plans and Procedures

45 days prior to the test even

O.1.4

Thermal Event Report

Microsoft Word document

Sign off from COR

Date of Option Award

(T) + 18 Months

Other Deliverable Requirements:

A. Reports: Reports will be 508- compliant to meet the Americans with Disabilities Act (ADA) requirements for external publication. Reports must be submitted electronically after approval of the PHMSA Technical POC. If monthly and/or final reports contain proprietary information, the Contractor is responsible for clearly communicating which material is proprietary and for internal eyes only. The Contractor must also provide an electronic copy of a public version of the final report covering all work completed. The Contractor must notify the PHMSA Technical POC if the Contractor intends to publish any of the project work in a peer-reviewed journal. All public reports must meet the requirements to be published in ROSAP, the Department of Transportation’s official public access repository.

B. Outreach Materials: All images and graphics in deliverables shall be vetted by the Contractor for copyright and attribution. The Contractor is responsible for obtaining appropriate permission for use of images that are not owned/licensed by the Contractor. The Contractor must provide sources and attribution information for images that are not created or generated by the Contractor.

8. Inspection and acceptance criteria The Contractor must provide and maintain an inspection system acceptable to the Government covering the work under this contract. Complete records of all inspection work performed by the Contractor shall be maintained and made available to the Government during contract performance and for as long afterwards as the contract requires.

(b) The Government has the right to inspect and test all work called for by the contract, to the extent practicable at all places and times, including the period of performance, and in any event before acceptance. The Government may also inspect the premises of the Contractor or any subcontractor engaged in contract performance. The Government shall perform inspections and tests in a manner that will not unduly delay the work.

(c) If the Government performs any inspection or test on the premises of the Contractor or a subcontractor, the Contractor shall furnish and shall require subcontractors to furnish, at no increase in contract price, all reasonable facilities and assistance for the safe and convenient performance of these duties. Except as otherwise provided in the contract, the Government shall bear the expense of Government inspections or tests made at other than the Contractor’s or subcontractor’s premises.

(d) The Government shall accept or reject the work as promptly as practicable after delivery, unless otherwise specified in the contract. Government failure to inspect and accept or reject the work shall not relieve the Contractor from responsibility, nor impose liability on the Government, for nonconforming work. Work is nonconforming when it is defective in material or workmanship or is otherwise not in conformity with contract requirements.

(e) The Government has the right to reject nonconforming work. If the Contractor fails or is unable to correct or to replace nonconforming work within the delivery schedule (or such later time as the Contracting Officer may authorize), the Contracting Officer may accept the work and make an equitable price reduction. Failure to agree on a price reduction shall be a dispute.

(f) Inspection and test by the Government does not relieve the Contractor from responsibility for defects or other failures to meet the contract requirements that may be discovered before acceptance. Acceptance shall be conclusive, except for latent defects, fraud, gross mistakes amounting to fraud, or as otherwise specified in the contract. If acceptance is not conclusive for any of these causes, the Government, in addition to any other rights and remedies provided by law, or under other provisions of this contract, shall have the right to require the Contractor-(1) At no increase in contract price, to correct or replace the defective or nonconforming supplies (work) at the original point of delivery or at the Contractor’s plant at the Contracting Officer’s election, and in accordance with a reasonable delivery schedule as may be agreed upon between the Contractor and the Contracting Officer; provided, the Contracting Officer may require a reduction in contract price if the Contractor fails to meet such delivery schedule; or

(2) Within a reasonable time after the Contractor’s receipt of notice of defects or nonconformance, to repayment of such portion of the contract price as is equitable under the circumstances if the Government elects not to require correction or replacement. When supplies (work) are (is) returned to the Contractor, the Contractor shall bear transportation costs from the original point of delivery to the Contractor’s plant and return to the original point of delivery when that point is not the Contractor’s plant.

9. Other pertinent information or special considerations Travel & ODCs Travel during the performance of this task order is anticipated as follows:

• In-person or virtual stakeholder briefings may be required, as requested by the COR.

• Travel to support the test event(s) The contractor must submit to the COR a travel request at least fifteen (15) days prior to travel with the cost of Airfare, Mileage, Car Rental, Lodging, Per Diem, and any other cost associated with the travel. The contractor must have prior approval in writing from the COR before traveling.

ODCs are incidental items needed to conduct the component and flight testing associated with this Task Order. ODCs may include but are not limited to, the procurement of drones (approved by the FAA), spare UAS parts such as batteries and propellers, and other miscellaneous items determined appropriate for completion of the work contained within this Task Order. All ODCs must have prior approval in writing from the CO before an ODC purchase can be made. The contractor must allow a minimum of fifteen (15) calendar days for the COR and CO to review and approve an ODC request.

Data Rights FAR 27.404-1 Unlimited rights data.

The Government acquires unlimited rights in the following data except for copyrighted works as provided in 27.404-3:

(a) Data first produced in the performance of a contract (except to the extent the data constitute minor modifications to data that are limited rights data or restricted computer software).

(b) Form, fit, and function data delivered under contract.

(c) Data (except as may be included with restricted computer software) that constitute manuals or instructional and training material for installation, operation, or routine maintenance and repair of items, components, or processes delivered or furnished for use under a contract.

(d) All other data delivered under the contract other than limited rights data or restricted computer software (see 27.404-2).

Research Agreement Terms and Conditions In response to the White House Office of Science and Technology Policy memorandum dated February 22, 2013, entitled Increasing Access to the Results of Federally Funded Scientific Research, the U.S. Department of Transportation (USDOT) is incorporating Public Access requirements into all funding agreements for scientific research. This section sets forth the requirements a funding recipient must satisfy to be in full compliance with the USDOT Public Access plan. For all wholly or partially federal funded scientific research agreements the Contractor /Awardee hereby agrees to comply with the requirements of the USDOT Public Access plan. Contractor /Awardee is required to include these obligations in any sub-contracts, awards or other related funding agreements. A copy of the USDOT Public Access plan can be viewed in full at:

https://www.transportation.gov/mission/open/official-dot-public-access-plan-v11 The full requirements of the DOT Public Access plan requirements include, but are not limited to, the following:

A. Copyright License Contractor /Awardee hereby grants to the USDOT a worldwide, non-exclusive, non-transferable, paid-up, royalty-free copyright license, including all rights under copyright, to any and all Publications and Digital Data Sets as such terms are defined in the USDOT Public Access plan, resulting from scientific research funded either fully or partially by this funding agreement. [Contractor /Awardee] herein acknowledges that the above copyright license grant is first in time to any and all other grants of a copyright license to such Publications and/or Digital Data Sets, and that USDOT will have priority over any other claim of exclusive copyright to same.

B. Reporting and Compliance Activities Contractor /Awardee hereby agrees to satisfy the reporting and compliance requirements as set forth in the USDOT Public Access plan, including, but not limited to, the submission and approval of a Data Management Plan, the use of Open Researcher and Contributor ID (ORCID) numbers, the creation and maintenance of a research project record in the Transportation Research Board’s (TRB) Research in Progress (RiP) database, and the timely and complete submission of all required publications and associated digital data sets as such terms are defined in the DOT Public Access plan. Additional information about how to comply with the requirements can be found at: http://ntl.bts.gov/publicaccess/howtocomply.html

April 3, 2025