New battery Regulation by U.S. Department of Transportation (DOT)
Introduced rule regarding the lithium batteries on Aug 6th, 2014 (79 FR 46012) will affect any shipment within or to, from on through the united state of America (including those shipped from or to Canada). This rule is enacted immediately as voluntarily, but any shipper must comply with this new rule by February 6, 2015.
This rule will affect any shipments of batteries alone or equipment powered by these batteries. The final rule may found through The Daily Journal of the United States Government.
The revised rule may require changes to the way in which one describe, package, mark, label and document your lithium battery shipments. DOT has adopted many of the requirements currently in place in the 2013-2014 ICAO Technical Instructions, which are the regulatory basis for the IATA Dangerous Goods Regulations. Ground shipments of lithium batteries, therefore, are now more closely aligned with the latest revision of the IATA Dangerous Goods Regulations as its requirements are known more stringent than the rules previously in place for ground shipments.
The revision by DOT is introduced in order to improve safety and reduce the number of incidents involving lithium battery shipments. The rules also will help to standardize the way in which lithium batteries and equipment powered by such batteries are shipped. In the past, ground shipments were under one set of requirements while air shipments were under another, more stringent set of standards. Under this new rule, most shippers will be able to standardize their shipping process. DOT has not made the lithium battery regulations more stringent than ICAO to avoid any possible negative impact on US battery manufacturers or shippers.
Before introduction of the new rule, only two entries for lithium batteries were listed in 49 CFR hazardous materials table. “UN3090, LITHIUM BATTERY, 9 II” that has been used to describe both lithium metal (non-rechargeable) batteries and lithium ion (rechargeable) batteries and “UN3091, LITHIUM BATTERIES PACKED WITH EQUIPMENT, 9, II” and “UN3091, LITHIUM BATTERIES CONTAINED IN EQUIPMENT, 9, II”, which have been likewise used to describe both lithium metal and ion batteries shipped with or in equipment.
Effective with introduction of the new changes, there will be six unique basic shipping descriptions listed in the HMT. These are identical to those currently found in ICAO/IATA and they must be used by the mandatory compliance date of February 6, 2015:
|Proper shipping name||UN number||Hazards class||PG|
|Lithium ion batteries||UN3480||9||II|
|Lithium ion batteries contained in equipment||UN3481||9||II|
|Lithium ion batteries packed in equipment||UN 3481||9||II|
|Lithium metal batteries||UN3090||9||II|
|Lithium metal batteries contained in equipment||Un3091||9||II|
|Lithium metal batteries packed in equipment||UN3091||9||II|
As another changes of revised rule of batteries, for years, shippers have been frustrated by the hazardous materials regulations which included equivalent lithium content (ELC) as a measure of the energy in a lithium ion battery. ICAO/IATA and IMDG has long used the more typical and easy to obtain Watt-hour (Wh) rating. To make identification even easier, under this new rule, battery manufacturers will be required to mark each lithium ion battery with the watt hour rating beginning in 2016. Under this new rule, DOT is removing all references to ELC and adopting watt-hours.
Under criteria of eth new revised rule, DOT is not changing the values the shipper uses to determine if a lithium battery is “small” and therefore “excepted” from the regulations. SMALL lithium metal cells are those containing < 1 g lithium per cell or < 2 g lithium per battery. These are still “excepted.” SMALL lithium ion cells are those rated at < 20 Wh per cell or < 100 Wh per battery. These also are still “excepted.” However, please read the “SMALL Lithium Battery Exceptions” and “MEDIUM Lithium Battery Exceptions” of this document for further information on the provisions of these exceptions.
SMALL Lithium Battery Exceptions
As the most significant changes in revised regulation, shippers of “small lithium batteries” who were relieved from most regulatory enforcement for ground transportation will now have to mark and label battery packages being shipped by ground the same way have been preparing them for air. For example, most packages containing < 24 cells or < 12 batteries were not required to be marked that they contained lithium batteries and they were not required to be accompanied by any special documentation; however, under criteria of the revised regulation they will need an appropriate marking and/or labeling as described in table below:
New Package Requirements for excepted Small lithium Batteries- Ground
|Package contains:||Numbers/ package||Package tests||Package weight limits|
|Lithium ion batteries||1 or more||1.2 m drop test||66 lb. (30 Kg) gross|
|Lithium ion batteries contained in equipment
|1 or more||None||None|
|Lithium ion batteries packed in equipment
|1 or more||1.2 m drop test||None|
|Lithium metal batteries
|1 or more||1.2 m drop test||66 lb. (30 Kg) gross|
|Lithium metal batteries contained in equipment
|1 or more||None||None|
|Lithium metal batteries packed in equipment
|1 or more||1.2 m drop test||None|
|Button cells contained in equipment
New Hazards Communications for Excepted Small Lithium Batteries- Ground
|Package contains:||Numbers/ package||Lithium Battery warning?||Primary Lithium Batteries Forbidden for Transport Aboard passenger Aircraft||Lithium Warning Documents?|
|Lithium ion batteries||1 or more||Yes||No||Yes|
|Lithium ion batteries contained in equipment||≤ 4 cells or
|≥ 4 cells or
|Lithium ion batteries packed in equipment||1 or more||Yes||No||Yes|
|Lithium metal batteries||1 or more||Yes||Yes. Marking is required regardless of numbers of batteries.||Yes|
|Lithium metal batteries contained in equipment||≤ 4 cells or
|No||Yes. Marking required for packages containing more than 11 lbs of batteries.||No|
|≥ 4 cells or
|Yes||Yes. Marking required for packages containing more than 11 lbs of batteries.||Yes|
|Lithium metal batteries packed in equipment||1 or more||Yes||Yes. Marking required for packages containing more than 11 lbs of batteries.||Yes|
Requirements for the shipment of small lithium cells and batteries by air under 49 CFR are now identical to those found in Section II (or 1B) of the relevant IATA packing instructions. Please refer to the 49 CFR or IATA regulations for complete requirements.
MEDIUM Lithium Battery Exceptions
Previously DOT has retained this exception for lithium metal cells containing up to 5 grams of lithium and lithium metal batteries containing up to 25 grams of lithium. Lithium ion cells rated up to 60 Wh and lithium ion batteries rated up to 300 Wh are also fall under criteria of medium lithium battery category. Shipments of medium batteries as described above are authorized for ground and vessel transportation only. All packages, regardless of number of batteries, must be marked with the words LITHIUM BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL.
In addition to the changes described till this point, DOT has also changed the requirements for prototype battery shipments and for the shipment of lithium batteries and cells for disposal or recycling. Additionally, for battery manufacturers, DOT has adopted the requirement that they retain a record that the batteries and cells they ship have passed UN testing. This record must be retained for as long as the battery is shipped and for 1 year after.