By Allison Proffitt
August 19, 2020 | James Powell with Transportation Development Group outlined the current state of lithium battery transport restrictions and highlighted a few upcoming changes. Powell has been involved in dangerous goods training since the late 1970s and has worked with governments and organizations around the world. At the end of 2019, he was in Africa training governments on the best ways to transport Ebola samples. Little did he know, he said, as he watched lab technicians move around in white “moon suits” that he’d come home to a pandemic here as well.
If you can’t ship your products to the marketplace, they are worthless, Powell pointed out. And shipping rules, surcharges, and procedures can impact costs. The U.S. Department of Transportation and Federal Aviation Administration consider lithium batteries a “ticking time bomb”, Powell said. And not without reason. Lithium battery fires are difficult to extinguish. They can reignite with only heat—not flame—and at relatively low temperatures. Lithium metal battery fires have been known to compromise the lining of the aircraft belly. And fires can start from simple impacts like dropping or minor manufacturing defects.
Because of these risks, shipper’s liability is very, very substantial; Powell pointed out a few examples. The FAA charged Massachusetts Institute of Technology $175,000 in fines when a researcher shipped 33 devices with lithium batteries via FedEx in a box not labelled for hazardous materials. A plastics company that makes the housing for a backup battery in a diesel engine fuel emissions monitoring system was charged a $75,000 penalty because the batteries were undeclared, even though there was no spill or damage.
And the regulations are complex. Packaging requirements change if shipped by ground, air, rail, or ship. Rules change based on the size and type of battery and whether the battery is alone, packaged with equipment, or installed in equipment. Primary (lithium metal) and secondary (rechargeable lithium ion) batteries are regulated differently. Powered vehicles enjoy more exceptions and are handled differently, Powell said. Class 9 batteries in impact-resistant casing have exceptions.
Cells are treated differently from batteries, and prototypes are the most tightly regulated. Powell recounts a Mars rover being tested in the lava fields of Hawaii. The battery prototype needed special approval before it could be transported to the testing site. (TDG offers a Lithium Battery Wizard to help sort out these options.)
Regulations also change depending on the package’s origin, destination, and route. International packaging rules, Powell said, are more consistent. But packages heading for, coming from, or passing through the United States must follow stricter guidelines.
Some recent changes in battery shipping regulations include a change in the acceptable size of the international lithium battery mark, but of more importance, Powell said, is the new Lithium Battery Test Summary required by the UN Manual of Tests and Criteria.
The Lithium Battery Test Summary is meant to facilitate compliance downstream in the supply chain from the manufacturer of the battery or cell to the intermediaries who do not themselves do any tests but want to ensure that it’s in compliance. Tests include altitude simulations, thermal tests, vibration tests, shock tests, external short circuit tests, impact tests, and more. The Summary is not required for transport, Powell explained, but someone may ask for it anyway and it would be very useful for companies and groups in the middle of the supply chain who don’t have firsthand knowledge of the tests and procedures in place earlier in the battery lifecycle.
Next year, new standards take affect from the International Air Transportation Association requiring competency-based dangerous goods training. Again, this will be less impactful in the U.S., Powell says, because the U.S. Department of Transportation already requires function-specific training for each job, safety and security training.
The mixed regulations raise many questions for battery transport. Powell emphasized that shipping lithium batteries—or products containing lithium batteries—is still a liability. “Your biggest exposure (other than lack of training) is vendors who may not know what they’re doing, and you reship or resell their product,” Powell said.
And what to do if your packages are flagged by authorities? Powell offered some advice: call your lawyer! Buy time, he said, to gather all of your information before responding to any requests. Make sure training records are complete and up to date, and train anyone who needs it immediately. Build a timeline of events. Gather phone and email records. If you must, freely offer safety information but do not comment on non-safety questions and certainly don’t sign anything!
Editor’s Note: Did you miss the 2020 International Battery Seminar? Because the event was virtual, you can still access the event including all of the recorded sessions, presentations, and materials. Register for PREMIUM POST-EVENT ON-DEMAND.