LITHIUM BATTERY TRANSPORTATION NEWS
JANUARY 14, 2021 UPDATE
There have been several updates to lithium battery regulations, however, only minor package marks/labels and documentation updates are noted. The most notable update is a reduced sized Lithium Battery mark (see IATA below).
2021 IATA DGR (62nd Edition) Update:
A88 updated to include requirements for state (country) of the operator (airline) to grant approval, in addition to the state of origin to ship prototype cells and batteries aboard Cargo Aircraft Only.
A99 updated to include requirements for state (country) of the operator (airline) to grant approval, in addition to the state of origin to ship packages containing in excess of 35 KG lithium batteries aboard Cargo Aircraft Only.
A154 was updated to address assessing if a lithium battery is damaged/defective.
PI 965-970 updated to address:
- Prohibition of damage/defective lithium batteries.
- Updated Air Waybill language, if shipping per Section II of multiple packing instructions.
PI 967 &970 updated to address:
- Equipment must be secured against movement within the outer package.
- Multiple pieces of equipment within must be packaged to prevent damage or contact with other equipment in the package.
Lithium Battery Mark (Figure 7.1.C)
The size of the lithium battery mark which is affixed to packages prepared according to Section II of PI 965-970 and Section IB of PI 965 & 968 was updated. The new minimum dimensions are 100 mm x 100 mm (61st Edition minimum dimensions were 120 mm x 110 mm). So, the mark described in the 61st Edition may continue to be used.
Section 18.104.22.168 of the 62nd Edition was updated to allow a lithium battery marking no less than 100 mm x 70 mm for smaller sized packages. However, where any face of a package is large enough to bear the full-size lithium battery mark, the full-size mark (100 mm x 100 mm) must be used.
This reduced size lithium battery mark has not been officially adopted in 49 CFR for use in the United States. However, PHMSA has issued an enforcement waiver allowing the reduced sized markings to be used in the U.S. by any mode of transport until officially adopted in a Final Rule. This waiver can be found at the following PHMSA link:
Many vendors sell the smaller markings. These markings are authorized beginning January 1, 2021. Be sure to review 22.214.171.124 for complete details.
MAY 11, 2020 49 CFR Update
49 CFR 173.185 (a) was updated to require battery manufacturers to have lithium battery test reports available.
49 CFR 173.185 (b)(2)(ii) was updated to specify that lithium cells and batteries including lithium cells or batteries packed with, or contained in, equipment, must be packaged in a manner that prevents damage caused by movement or placement within the package.
49 CFR 173.185 (b)(3)(i) was updated to specify that inner packagings must be separated from electrically conductive materials.
49 CFR 173.185 (c)(2) was updated to except equipment containing small or medium batteries that is robust enough to protect lithium batteries from damage or short circuits from the requirement to be packaged.
49 CFR 173.185 (c)(3)(iii) was added to require that when packages of lithium cells or batteries required to bear the lithium battery mark are placed in an overpack, the lithium battery mark must either: (1) Be clearly visible through the overpack; or (2) the lithium battery mark must also be affixed on the outside of the overpack, and the overpack must be marked with the word ‘‘OVERPACK’’ in lettering at least 12 mm (0.47 inches) high.
49 CFR 173.185 (c)(4)(vi) was updated to state that up to ‘‘two spare sets’’ of cells or batteries can be placed in a package with equipment. For the purposes of this paragraph, a spare set is equal to the number of individual spare cells or batteries required to power each piece of equipment. This paragraph is applicable to air transport of small lithium batteries packed with or contained in equipment.
49 CFR 173.185 (e)(1)&(2) were updated to specify that cushioning material must be electrically nonconductive instead of the former ‘‘nonconductive’’ requirement. 49 CFR 173.185 (e)(4) was added to authorize the use of certain rigid large packagings to transport a single large battery or a single large item of equipment. 49 CFR 173.185 (e) addresses shipments of prototype lithium batteries (not UN 38.3 tested).
49 CFR 173.185 (f) addresses damaged/defective lithium batteries. 49 CFR 173.185(f)(2) was amended to specify that cushioning material must be electrically non-conductive, which harmonizes the HMR with the international standards. PHMSA also amended § 173.185(f)(3) to clarify the provisions for the use of large packagings.
2021 HAZMATEAM LITHIUM BATTERY SHIPPING GUIDE
The December 28, 2020 version of the 2021 HAZMATEAM LITHIUM BATTERY SHIPPING GUIDE provides a summary of these updated regulations, including illustrations of package marks/labels, Dangerous Goods Declaration form examples, package testing requirements and emergency response information.
The 2021 Lithium Battery Guide incorporates a summary of requirements described in the 62nd Edition (2021) of the IATA DGR, the latest DOT requirement specific to lithium batteries (49 CFR 171-180 in effect 1-Jan-2021) and Amendment 39-18 of the IMDG Code. Always consult the regulations for the complete rules. However, the Guide is a great starting point…
The 2021 HAZMATEAM Lithium Battery Shipping Guide has several new additions and updates:
- UN 3171, Battery-Powered Vehicles. This is not a new proper shipping name. However, with lithium battery powered vehicles (e-bikes, tractors, robots moving goods, etc.) becoming more common, we added a new section to the Guide addressing shipping UN 3171. The new Guide section includes package marking/labeling requirements and documentation requirements when shipping UN 3171 via ground, air or vessel transport. The 2021 Guide also clarifies the definition of “vehicle”. The shipping requirements are significantly less stringent for shipping UN 3171 compared to shipping UN 3481 or UN 3091.
- 2020 ERG. US DOT released the 2020 Emergency Response Guidebook back in May. The 2021 HAZMATEAM Lithium Battery Shipping Guide has been updated to include the updated lithium battery ERG Guide Pages (Guides 138 and 147).
HAZMATEAM Lithium Battery Shipping Guide Revision History
January 14, 2021 --- Emergency Response Guides information was updated to reflect the 2020 Emergency Response Guidebook. A new “UN 3171, Battery-Powered Vehicle” section was added to the Guide.
January 3, 2020 --- Updated to reflect lithium battery test reports, use of the term ‘aggregate lithium content’ and segregation requirements if shipping per IATA PI 965 or 968.
March 18, 2019 … Updated to reflect HM-224I.
October 21, 2018 ... Updated to reflect 2019 (60th Edition) IATA DGR and 2018, Amendment 39-18 of IMDG Code. Shipping paper examples updated to reflect new IATA declaration format and hybrid battery description.
November 28, 2017 … Updated to reflect 2018 IATA DGR. Sections added to the Guide: Package performance testing requirements and Emergency Response requirements. We also doubled the number of shipping paper (BOL and declarations) examples and re-formatted the battery size definition sections for clarity.
March 31, 2017 … Incorporation of HM-215N following the re-release of the final rule on March 30, 2017.
March 15, 2017 … Incorporation of 27-Feb-2017 DOT Notice. Also, updated to clarify use of address labels on packages.
February 1, 2017… Removal of HM-215N requirements as a result of Regulatory Freeze executive memorandum
January 22, 2017… Incorporated HM-215N DOT final rule
January 1, 2017 …Incorporated 2017 DOT, IMDG and IATA Updates
May 17, 2016 ... Incorporated 2016 ERG Guide pages; clarified scope of Guide; added disclaimer