LITHIUM BATTERY TRANSPORTATION NEWS
April 12, 2024 UPDATE
A harmonization final rule, DOT HM-215Q, was issued by DOT PHMSA in the April 10, 2024 FR. Highlights of this update includes:
1) Removal of the requirement to include a telephone number on the lithium battery handling mark, 49 CFR 173.185 (c)(3). This update was recently made in the 64th Edition (2023) of IATA Dangerous Goods Regulations and the 41-22 Amendment (2022) of the IMDG Code. All three regulations allow the old mark, with the telephone number, to be used until December 31, 2026 (DOT: 49 CFR 173.185 (c)(3); IATA DGR: 7.1.5.5; IMDG Code: 5.2.1.10.2).
2) Removal of the exception in 49 CFR 173.185 (c)(4). This air transportation exception allowed one package to contain up to 2 small lithium ion batteries (UN 3480) or 2 small lithium metal batteries (UN 3090) without a Dangerous Goods Declaration form. This aligns with the update to the 63rd Edition (2022) of the IATA DGR that eliminated PI 965 Section II and PI 968 Section II. So, all air shipments of any size UN 3480 or UN 3090 must be accompanied by a Dangerous Goods Declaration form.
On April 4, 2024 DOT PHMSA released the electronic versions of the 2024 Emergency Response Guidebook. Updates relative to lithium batteries include an updated ERG GUIDE 147 (updated fire fighting procedures) and a new section "Considerations for Lithium Battery and Electric Vehicle (EV) Fires".
Coming in 2025 - Major updates to Lithium Battery Regulations including new proper shipping names: "UN 3557, Vehicle, Lithium Metal Battery Powered" and "UN 3558, Vehicle, Lithium Ion Battery Powered" - these entries will be used instead of "UN 3171, Battery-Powered Vehicle" when a vehicle is solely powered by a lithium metal battery or lithium ion battery, respectively. There will also be four new proper shipping names for "Sodium Ion Batteries". Stay tuned...
January 19, 2023 UPDATE
The 64th Edition (2023) of the IATA DGR includes the following updates related to air shipments of Lithium Batteries:
Lithium Battery Mark
The requirement to include a telephone number on the Lithium Battery Mark (IATA 7.1.5.5, Figure 7.1.C) has been eliminated. The Lithium Battery Mark may include the telephone number until 31-December-2026. The lithium battery mark is affixed to packages containing small lithium metal/ion batteries.
HOWEVER, DOT PHMSA has not yet issued a rulemaking for removal of the telephone number on the mark. Harmonization rules are typically finalized in the summer. So for domestic US shipments, continue to use lithium battery mark with the telephone number until DOT issues a final rule.
   
Activated Tracking Device (such as Data Loggers) for Air Shipments
IATA Special Provision A220 provides an exception to small lithium metal batteries contained in equipment and small lithium ion batteries contained in equipment when the equipment is an activated tracking device. This exception is for activated equipment, such as data loggers, not for equipment shipped as cargo. The exception is applicable to tracking devices used for COVID-19 pharmaceuticals shipments and/or shipments where prior arrangements have been made with the operator (airline). When shipped per A220, the shipper is excepted from marking and documentation requirements. See below for DOT (49 CFR) exceptions for activated tracking devices shipped ground and vessel below. See the HAZMATEAM Lithium Battery Shipping Guide for more details.
Stack Test for Package of Small Lithium Ion Batteries (UN 3480) and Small Lithium Metal Batteries (UN 3090)
Packages prepared according to IATA PI 965 Section IB (small lithium ion batteries without equipment, UN 3480) and IATA PI 968 Section IB (small lithum metal batteries without equipment, UN 3090) are now required to be capable of passing a stack test. This test is in addition to the drop test.
DOT 49 CFR UPDATE
US DOT PHMSA issued a final rule on December 21, 2022. This final rule revises the Hazardous Materials Regulations for lithium cells and batteries transported by aircraft and is consistent with the previously published Interim Final Rule, which responded to congressional mandates; prohibited the transport of lithium ion cells and batteries as cargo on passenger aircraft; required lithium ion cells and batteries to be shipped at not more than a 30 percent state of charge aboard cargo-only aircraft when not packed with or contained in equipment; and limited the use of alternative provisions for smaller lithium cell or battery shipments to one package per consignment. A new marking option has been added to 49 CFR 173.185 (c)(1)(iii), "“LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”. Refer to the HAZMATEAM Lithium Battery Shipping Guide for details. The effective date for the December 21, 2022 FR is January 20, 2023.
US DOT PHMSA issued an update related to activated tracking devices in the 26-July-2022 Federal Register. Any size of a lithium metal battery contained in equipment or any size of a lithium ion battery contained in equiment used as an activated tracking device has several exceptions when shipped ground and vessel transport. The exceptions are only applicable if the equipment is an activated tracking device (such as a data logger), not when shipping the equipment as cargo. When shipped per 49 CFR 173.14 (a), ground and vessel shipments of activated tracking devices do not need shipping papers, marks and labels. For ground and vessel shipments, the exception is not limited to COVID-19 pharmaceuticals and approvals are not required. See 49 CFR 173.14 and the HAZMATEAM Lithium Battery Shipping Guide for more details.
NOVEMBER 22, 2021 UPDATE
IATA announced two significant changes to lithium battery transportation requirements, one rule that takes effect on January 1, 2022 and another that goes into effect on January 1, 2023
Changes to IATA DGR 63rd Edition (2022)
PI 965 and PI 968—Have been revised to remove Section II from these two packing instructions. To provide shippers with time to adapt their logistics processes to ship lithium cells and batteries in accordance with Section IB of Packing Instruction 965 and Packing Instruction 968, as applicable, there is a 3-month transition period until 31 March 2022, during which time shippers may continue to use Section II.
This change is only applicable to small lithium batteries shipped without equipment: UN 3480 and UN 3090
Check out the 2022 Hazmateam Lithium Battery Shipping Guide. The 2022 Lithium Battery Shipping Guide summarizes this update.
HAZMATEAM Lithium Battery Shipping Guide Revision History
April 11, 2024 - Updated lithium battery handling marks (removal of telephone number) per DOT HM-215Q. Also, emergency response information (ERG Guide 147) was updated following the April 4, 2024 release of the 2024 Emergency Response Guidebook.
January 1, 2024 - Addition of USPS hazmat rules.
January 19, 2023 - Correction to small UN 3091 air page
January 14, 2023 - Addition of activated tracking device rules; added a new OVERPACK guidance page; updates to the lithium battery handling mark; new markings according to 49 CFR 173.185 (c)(1)(iii)
January 1, 2022 - Removal of IATA PI 965/968 Section II
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
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