Preparing Shipments of Lithium Batteries for Air Transport
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The transport of lithium batteries and articles containing lithium batteries is probably the most talked-about subject among the lawmakers and regu- lators of dangerous goods worldwide. At this time such notable regula- tory agencies as the UN/ICAO Dangerous Goods Committee and the US DOT PHMSA are working on new laws and regulations which will further restrict and limit the ability to ship this commodity by air. The reason: air incidents involving lithium batteries. There have been fires and smok- ing packages found at various times aboard aircraft in the past few years, caused by overheated batteries. The regulatory bodies heavily regulate the air cargo shipment of lithium batteries, as described in this brief discussion. Preparing Shipments of Lithium Batteries for Air Transport White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2 1
Transcript of Preparing Shipments of Lithium Batteries for Air Transport
The transport of lithium batteries and articles containing lithium batteries
is probably the most talked-about subject among the lawmakers and regu-
lators of dangerous goods worldwide. At this time such notable regula-
tory agencies as the UN/ICAO Dangerous Goods Committee and the US
DOT PHMSA are working on new laws and regulations which will further
restrict and limit the ability to ship this commodity by air. The reason:
air incidents involving lithium batteries. There have been fires and smok-
ing packages found at various times aboard aircraft in the past few years,
caused by overheated batteries. The regulatory bodies heavily regulate the
air cargo shipment of lithium batteries, as described in this brief discussion.
Preparing Shipments of Lithium Batteries for Air Transport
White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
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The term “lithium batteries” as defined by ICAO/IATA refers to a family
of batteries with different chemistries, comprising many types of cathodes
and electrolytes. There are two kinds of lithium batteries that fall under the
Dangerous Goods Regulations:
Rechargeable -- batteries that lose their charge, and thus their potency,
and must be plugged into a charger in an electrical socket, used in laptops,
cell phones and other consumer electronics; these are lithium ion (Li-ion)
and lithium polymer batteries
Non-rechargeable (Primary) -- batteries that keep their charge, and
thus their potency, and do not require frequent recharging, used in aircraft
parts and other industrial equipment; these are lithium metal and lithium
alloy batteries.
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Definition of Lithium Batteries
White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
Lithium Ion, Lithium Polymer Rechargeable Batteries
When these batteries meet the criteria for being Dangerous Goods, the UN
Number and Proper Shipping Names are:
UN 3480 LITHIUM ION/POLYMER BATTERIES
UN 3481 LITHIUM ION/POLYMER BATTERIES PACKED
WITH EQUIPMENT
UN 3481 LITHIUM ION/POLYMER BATTERIES CONTAINED
IN EQUIPMENT
These Rechargeable Lithium Batteries are considered “Excepted” under
the IATA Dangerous Goods Regulations (DGR) if they meet the following
criteria:
1. Battery is less than 100 wh (the wh is marked on the battery itself, for
example, laptop batteries are around 55 wh)
2. Cells less than 20 wh
3. It must meet all of the laboratory tests outlined in the United Nations
Test Manual
Most lithium ion batteries manufactured by leading companies such as
Toshiba, Sony, and so forth meet both criteria.
Those lithium ion or lithium polymer batteries not meeting these criteria
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
The IATA Regulations for Shipping Lithium Batteries by Air
must be shipped as Dangerous Goods, Class 9, under the specific provi-
sions of DGR Packing Instructions 965-967 respectively. These provi-
sions are too numerous to be detailed here. Read the packing instructions
carefully for specific instructions on DG shipping.
Lithium Metal/Alloy Primary (non-rechargeable) Batteries
When these batteries meet the criteria for being Dangerous Goods, the UN Number and Proper Shipping Names are:
UN 3090 LITHIUM METAL/ALLOY BATTERIESUN 3091 LITHIUM METAL/ALLOY BATTERIES PACKED WITH EQUIPMENTUN 3091 LITHIUM METAL/ALLOY BATTERIES CONTAINED IN EQUIPMENT These Non-Rechargeable Lithium Batteries are considered “Excepted” under the IATA Dangerous Goods Regulations (DGR) if they meet the following criteria:
1. Each cell content not more than 1 gram2. Battery aggregate lithium content not more than 2 grams 3. It must meet all of the laboratory tests outlined in the United Nations Test Manual
Those lithium metal or lithium alloy batteries not meeting these criteria must be shipped as Dangerous Goods, Class 9, under the specific provi-
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
The IATA Regulations for Shipping Lithium Batteries by Air
sions of DGR Packing Instructions 968-970 respectively. These provi-sions are too numerous to be detailed here. Read the packing instructions carefully for specific instructions on DG shipping.
Note that the IATA Regulations authorize this commodity for passenger aircraft, but some governments and airlines restrict it to Cargo Air-craft Only. You must check all State and Operator Variations to ensure that it can legally fly on a passenger aircraft.
The Handling Label
Packages prepared using Section II (“Excepted”) of PI’s 965, 966, 968, and 969 must bear the Lithium Battery Handling Label and the label must include the type of battery (lithium ion, lithium metal).
Labeling, Documentation and Packaging
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
Packages prepared using Section II (“Excepted”) of PI’s 967 and 970, where the package contains more than 4 (four) cells or more than 2 (two) batteries installed in equipment must bear the Lithium Battery Handling Label and the label must include the type of battery (lithium ion, lithium metal).
Each consignment with packages bearing the Lithium Battery Handling Label must contain on the Air Waybill the following information indicat-ing that:
1. There are packages containing lithium batteries (either ion or metal)2. The packages are possibly flammable if damaged and must be handled with care3. If damaged, the package must be examined and possibly repackaged4. A telephone number for more information5. The words: “lithium metal batteries or lithium ion batteries as appropriate – not restricted per PI (the appropriate PI number)
Example of a Package
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
Labeling, Documentation and Packaging
Example of a Shipper’s Declaration
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
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The DOT’s Office of Hazardous Materials Transportation, a division of the PHMTSA, has issued regulations that must be followed when ship-ping Non-Rechargeable (Primary) lithium batteries to, from, or within the United States or on US flag-carrier airlines outside of the USA. Compli-ance is not required for shipments not transiting the USA. Details of these regulations can be found in the DGR under USG-02 but are summarized here.
The main provisions of the US regulations are:
Loose Primary Lithium Batteries not contained in or packed with equipment:
1. Primary lithium batteries (UN3090) carried loose and not with equip-ment are forbidden for transport aboard passenger aircraft to, from, and within the USA
2. If the shipment falls into the “Exceptions” category in PI 968 it may not be carried on passenger aircraft and the package must be marked:
PRIMARY LITHIUM BATTERIES (or alternatively LITHIUM METAL BATTERIES) – FORBIDDEN FOR TRANSPORT ABOARD PASSEN-GER AIRCRAFT
3. If the shipment is required to be shipped as Class 9 per PI 968, the Shipper’s Declaration must be marked: Cargo Aircraft Only and the package must bear the CAO label
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
The United States Government (DOT) Regulations
The United States Government (DOT) Regulations
Primary Lithium Batteries contained in or packed with equipment:
1. Primary lithium batteries contained in or packed with equipment (UN 3091) are forbidden for transport aboard passenger aircraft to, from, and within the USA UNLESS the shipment meets the criteria detailed in USG-02 2. If the shipment meets the criteria in USG-02 and in PI 969 or 970 for “Exceptions” then it must comply with those Packing Instructions and may be carried on a passenger aircraft
3. If the shipment does not meet the criteria in USG-02 but does meet the criteria in PI 969 or 970 for “Exceptions” then it may not be carried on a passenger aircraft and the package must be marked:
PRIMARY LITHIUM BATTERIES (or alternatively LITHIUM METAL BATTERIES) – FORBIDDEN FOR TRANSPORT ABOARD PASSEN-GER AIRCRAFT
4. If the shipment meets the criteria in USG-02 and in PI 969 or 970 for Class 9 then it must comply with those Packing Instructions and may be carried on a passenger aircraft; the package must not bear the Cargo-Air-craft-Only label
5. If the shipment does not meet the criteria in USG-02 but does meet the criteria in PI 969 or 970 for Class 9 then it may not be carried on a passenger aircraft and the package must bear the Cargo-Aircraft-Only label
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
Conclusion While the regulations may seem overly technical, it all boils down to this... what exactly are you shipping? Lithium Ion or Lithium Metal? Loose batter-ies or batteries contained in or packed with equipment?
Providing the courier or forwarder with precise information with respect to the type of battery, whether or not it is contained in equipment, and whether or not it meets the criteria of USG-02 is absolutely essential in order for us to comply with the regulations when tendering to the airline and properly route your shipment.
At least there is one piece of good news: shippers who use the services of couriers or freight forwarders do not have to be concerned about air waybill completion; that is the responsibility of the courier/forwarder.
Anyone having questions or wishing to discuss this issue with a transporta-tion professional should contact Quick International Courier, and we would be happy to talk it over with you.
About the Author Michael Gotz has developed IATA-certified Dangerous Goods train-ing programs and has been a panelist in numerous IATA Dangerous Goods international conferences. Michael is the author of published journal articles on the subject of the air transport of hazardous com-modities, and is responsible for employee and customer training and regulatory updating, and shipment troubleshooting for the Quick Group of Companies.
For more information, contact: Michael Gotz, Director of Dangerous Goods Quick Group of Companies Tel : +1 917 613 9290 or email: [email protected] www.quickintl.com
About Quick International Courier:A global solutions provider, Quick has been meeting critical deadlines with care and urgency for over 30 years. Quick delivers fast and reli-able door-to-door service for shipping blood and organs for transplant, to critical high-tech parts and medical devices, to crucial time-sensitive and highly confidential documents. Quick sets the standards for the priority transportation industry and provides an unparalleled level of service.
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White Paper: Preparing Shipments of Lithium Batteries for Air Transport, v.2
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