LITHIUM BATTERY TRANSPORTATION NEWS
JANUARY 3, 2020 UPDATE
Compared to previous years, the start of 2020 is bringing only a handful of minor updates to the regulatory requirements for shipping lithium batteries.
2020 IATA DGR (61st Edition) Update:
Lithium Battery UN Test Reports
IATA DGR Section 184.108.40.206.1 (g) requires lithium battery manufacturers and/or subsequent distributors to make available the test summary as specified in the UN Manual of Tests and Criteria, Part Ill, sub-section 38.3, paragraph 38.3.5. This is applicable for cells or batteries manufactured after 30 June 2003.
This document does not have to be included with each shipment. It could be made available on a battery manufacturer’s or a distributor’s website. One way or the other, a shipper needs to verify the battery they wish to ship has passed all the required UN tests.
Aggregate Lithium Content
The lithium metal battery packing instructions (PI 968-970) now use the term ‘aggregate lithium content’ to describe the size of a small vs. fully regulated lithium metal battery. The size definitions have not changed (small cell contains no more than 1 gram of lithium metal; small battery contains no more than 2 grams of lithium metal). Its just a new term used in the IATA Dangerous Goods Regulations.
Aggregate lithium content means the sum of the grams of lithium content contained by the cells comprising a battery.
The 2020 HAZMATEAM Lithium Battery Shipping Guide has been updated to address the updates.
2020 DOT (49 CFR 171-180) Update:
We are not anticipating any new Lithium Battery final rules soon.
The last update to Lithium Battery regulations in the DOT regulations were made on March 6, 2019 (HM-224I). See below for a summary of those updates.
IMDG CODE Update:
Look for the updated IMDG Code (Amendment 40-20) in September 2020.
DOT EMERGENCY RESPONSE GUIDEBOOK (Orange Book) Update:
Look for the 2020 Emergency Response Guidebook sometime around May 2020.
Many of you use ERG 138 and/or ERG 147 for written ER information required to accompany lithium battery shipments to stay in compliance with 49 CFR 172.602 (b).
We will update this page and the HAZMATEAM Lithium Battery Shipping Guide (see below) when there are new updates available!
MARCH 2019 Update
HM-224I was issued by PHMSA on March 6, 2019. Most of these rules were issued by ICAO/IATA back in 2016 and restrict the air transportation of UN 3480, Lithium Ion Batteries (no equipment):
- All sizes prohibited for passenger aircraft
- All sizes may not exceed a state of charge of 30%
- A limit of one package of small batteries per consignment shipped without a declaration
If you have been using the IATA Dangerous Goods Regulations (DGR) for the past 3 years, the above restrictions are nothing new, as 49 CFR has finally caught up with the international regulations.
However, HM-224I has package marking implications for small batteries shipped as UN 3480 via all modes of USA transport. Effective March 6, 2019, packages shipped ground, rail or vessel must be marked: ‘‘LITHIUM ION BATTERIES— FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT’’ or labeled with a ‘‘CARGO AIRCRAFT ONLY’’. Examples are as follows:
This new package marking requirements for UN 3480 is similar to the ground/rail/vessel marking requirements for packages containing small non-rechargeable lithium metal batteries without equipment, UN 3090.
If your package of UN 3481 (Lithium Ion Batteries Packed with Equipment or Lithium Ion Batteries Contained in Equipment) contains greater than 5 KG of small batteries per package the new marking rule takes effect, as well. Examples package markings:
Small lithium ion cells have a maximum watt hour rating of 20 Wh and small lithium ion batteries have a maximum watt hour rating of 100 Wh.
The HAZMATEAM LITHIUM BATTERY SHIPPING GUIDE summarizes package marking and labeling requirements for all sizes of rechargeable and non-rechargeable lithium batteries shipped all modes of transport.
HM-224I provides a new exception for UN 3480 for medical devices. These batteries are allowed on a passenger aircraft if the intended destination of the cells or batteries is not serviced daily by cargo aircraft if a cell or battery is required for medically necessary care. These batteries are also exempt from 30% maximum state of charge limitation. Both exceptions require an approval from PHMSA. See 49 CFR 173.185 (g) for this requirement.
The following rules took effect on 1-Jan-2019:
- Hybrid Batteries. Lithium battery technology continues to evolve. Batteries that contain both lithium ion cells and lithium metal cells (we will call these "hybrid batteries") must be shipped as UN 3090 or UN 3091, as appropriate. This is described in IMDG Code (Amendment 39-18) Special Provision 387 and IATA DGR (60th Edition) Special Provision A213. Further, these special provisions indicate that in order to ship these batteries as "small" lithium metal batteries, the total lithium content of all lithium metal cells contained in the battery must not exceed 1.5 grams and the total capacity of the all lithium ion cells contained in the battery must not exceed 10 Wh. Small lithium metal battery requirements are described in Section II of IATA DGR PI 968, 969 and 970 and in IMDG Code Special Provision 188. US DOT, 49 CFR, has not yet published any rulings on this topic - we do anticipate this update in early 2019.
- IATA Declaration. The declaration appearing in Section 8 of the 60th Edition (2019) of the IATA DGR has been updated. The updates are minor: the word "risk" has been replaced by "hazard" and the following portions have been removed from the form: "title of signatory" and "place". The old version of declaration may be used until 31-December-2024 (see IATA DGR 220.127.116.11). The declaration examples in the 2019 HAZMATEAM Lithium Battery Guide reflect the updated declaration form.
- IATA Emergency Response Drill Codes. ERG Code shown in Column N of the IATA DGR, for all lithium battery entries has been changed from "9FZ" to "12FZ". This reflects a change to identify that the inherent hazard for lithium batteies is not "9 - No general inherent risk" and a new drill number "12-Fire, heat, smoke, toxic and flammable vapour", was adopted.
- Lithium Battery Marking transition period is over. The following two Lithium Battery markings for small and medium lithium batteries are obsolete on January 1, 2019. If you use these old CAUTION! markings, your package will get rejected by the carrier!!
When required, you can only use the marks below on package containing small and medium lithium batteries. Please refer to the HAZMATEAM Lithium Battery Guide for use of these markings.
Note: effective 1-Jan-2018 IATA, Section 18.104.22.168.2 indicates the UN and number should be at least 12 mm high.
- If your package of lithium batteries requires a Class 9 label (all fully regulated packages and Section IB of IATA PI 965 or 968), you must use the Class 9/Lithium Battery label below. If you use the standard Class 9 label (without the burning battery illustration), your package will be rejected.
- IATA segregation requirements for UN 3480 and UN 3090:
- Packages or overpacks containing UN 3480 or UN 3090 cannot be packed with Class 1 other than Division 1.4S, Division 2.1, Class 3, Division 4.1 or Division 5.1. These are requirements for packages prepared according to PI 965 Sections IA & IB and PI 968 Sections IA & IB
- Cells and batteries packaged according to PI 965 Section II or 968 Section II cannot be packed in the same outer packaging with other Dangerous Goods.
- Effective 1-Jan-2019, all air, ground & vessel consignments of more than 2 packages of small lithium batteries contained in equipment must be marked with the lithium battery handling mark.
2020 HAZMATEAM LITHIUM BATTERY SHIPPING GUIDE
The January 3, 2020 version of the 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 2020 Lithium Battery Guide incorporates a summary of requirements described in the 61st Edition (2020) of the IATA DGR, the latest DOT requirement specific to lithium batteries (49 CFR 171-180 in effect 1-Jan-2020) and Amendment 39-18 of the IMDG Code. Always consult the regulations for the complete rules. However, the Guide is a great starting point…
HAZMATEAM Lithium Battery Shipping Guide Revision History
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 Editiion) 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