Lithium Battery Transport Regulations

Transcription

1 Lithium Battery Transport Regulations Edition 6 May 2008 In line with Saft s commitment of putting our customers at the heart of our business, we feel it is our duty to keep you inmed about the regulations governing the transport of lithium cells and. Please find below answers to some of the more frequently asked questions in this quite complex field. Such answers, given in good faith, do not dispense you from reading the original official documents relative to the subject. 1 To whom do these regulations apply? All those who ship lithium electrochemical cells and with or within equipment or in bulk m (meaning in any quantity but not packed with or contained in. Saft itself, but also all battery assembly companies, distributors, retailers, OEMs, etc. dealing with lithium products of all brands are concerned, since the one who ships is the one responsible compliance with the transport regulations. The regulations apply to domestic and international shipments, whatever their mode (by air, sea or land). 2 Which products are covered by these transport regulations? Primary (non-rechargeable) lithium cells (that contain lithium metal), as well as assembled from such cells. Rechargeable lithium-ion cells and, although these products do not contain any lithium in metal m, but just as ions. Note: Within the transport regulations documents, a cell is defined as a single encased electrochemical unit which exhibits a voltage differential across its two terminals. This can be understood as a power source already sealed, but not yet fit with final terminals and s. When these are in place, the product may become a single-cell battery or a multi-cell battery pack if two or more cells are permanently connected in series, parallel, or seriesparallel combinations. 3 Who is in charge of the transport regulations? The United Nations organization, based in Geneva and New York, runs years a Sub-Committee of Experts on the Transport of Dangerous Goods that has the authority to make recommendations relative to the transport of dangerous goods, whatever their type (explosives, ammunitions, viruses, etc.) For lithium and lithium-ion, these recommendations appear in the following two key documents: - Recommendations on the Transport of Dangerous Goods Model Regulations 15 th Revised Edition Ref. ST/SG/AC.10/1/Rev.15 - Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria 4 th Revised Edition Ref. ST/SG/AC.10/11/Rev.4/Amend.2 These documents may be amended periodically, following proposals made by representative of the battery industry, national administrations, or professional associations which may feel concerned by transport safety. In this document, the regulations not eseen to change in the immediate future are written in black letters, the ones bound to change are written in green, the ones that will become applicable at an already defined date are written in orange. The recommendations (often referred to as the UN Model Regulations ) are incorporated in the latest editions of the official Handbooks and Codes, thick documents that are regularly issued and updated by various bodies in charge of regulating transport modes.

2 Some have international authority: - The International Air Transport Association (IATA) issues every year its Dangerous Goods Regulations that come in accordance with the International Civil Aviation Organization (ICAO) s Technical Instructions the Safe Transport of Dangerous Goods following decisions made by a specific Dangerous Goods Panel. - The International Maritime Organization (IMO), based in London, issues regularly an International Maritime Dangerous Goods Code. Other bodies have just a regional authority: - The Inland Transport Committee of the Economic Commission Europe issues yearly a new edition of the Restructured ADR, which is a European agreement (adopted by more than 35 countries) concerning the international carriage of dangerous goods by road. - The Pipeline and Hazardous Materials Safety Administration, within the U.S. Department of Transportation (DOT) has the authority coordinating the air, sea, and land transportation of hazardous material within the USA. The corresponding regulations are published in the so-called Title 49 of the U.S. Code of Federal Regulations that appears in the Federal Register daily paper. While the regulations issued by the above bodies are generally harmonized with the UN Model Recommendations, there may be differences. A given UN Special Provision may be considered as not applicable to their specific transportation mode (For instance, air transport IATA/ICAO does not accept the transport of un-tested short production runs that the UN explicitly allows; the U.S. DOT bans restricted primary lithium from, etc.). 4 Which lithium products benefit from special dispositions in the transport regulations? Five product categories can be mentioned: within personal belongings, spares, prototypes, short production runs and spent According to IATA, consumer electronic devices containing lithium or lithium-ion cells or, such as watches, calculating machines, cameras, cellular phones, lap-top computers, camcorders, etc. when carried by air s or crew personal use are permitted aboard as carry-on baggage or checked baggage, without the approval of the operator or pilot-in-command. In other words, they are considered as personal belongings which a transport certificate and specific packaging, and labelling are not requested. The above notions may be extended to some battery-operated devices considered as tools personal use. The U.S. DoT is more restrictive. Equipment with lithium installed within is permitted in checked and carryon baggage as long as the battery content does not exceed 2 grams of lithium metal (if primary are concerned) and 25 grams of equivalent-lithium metal ( rechargeable product). Lithium-ion with an equivalent lithium metal content in the 8-25 gram range can be taken as checked or carry-on baggage as long as there is not more than 2 pieces of equipment concerned. There are no limits with an equivalent lithium content below 8 grams Spare the above devices are allowed aboard : - in the USA, in carry-on luggage only, as long as they are individually protected against short circuit. Primary cannot exceed 2 grams of lithium metal content, Rechargeable ones cannot exceed 8 grams of equivalent lithium content (see definition in 5). with equivalent Li content in the 8-25 gram range can be taken aboard, but their number is limited to 2 units (preferably packed in their original retail packaging or inside plastic zip-lock bags). spares with more than 25 grams of equivalent Li content are prohibited. - outside the USA, s can keep, in carry-on luggage only, with approval of the airline, up to 2 spare (not primary ones) as long as their declared nominal energy (see definition 5) is between 100 and 160 Watt-hours Prototypes shipped testing purposes, benefit from a modified transport procedure, whatever the transportation mode considered (see 9) Production runs not exceeding 100 units, also benefit, in some cases, from specific transport procedure (see 10) Cells and with a liquid cathode containing sulfur dioxide (SO 2), thionyl chloride (SOCl 2) or sulfuryl chloride (SO 2Cl 2) which have been discharged to the extent that their open circuit voltage is lower than 2 V or 2/3 of the undischarged voltage are banned from air transport. (Note: Experience shows that just fully discharged products are concerned by this later disposition). 2

3 5 What do transport regulations basically say about Li and cells and? In the field of dangerous goods, the UN Model Regulations list nine Hazard Classes. Lithium cells and, primary and rechargeable, as other miscellaneous substances and articles are normally assigned to the. At the time of writing these FAQ, the applicable UN Identification Numbers (that need to be used labelling and declarations) are : - UN 3090, primary and transported in bulk, - UN, primary and contained in equipment or packed with it. For the specific case of vehicles transported by air and containing a lithium battery : - UN 3166, flammable liquid-powered vehicles with lithium battery installed (hybrid vehicles), - UN 3171, battery-powered vehicles (electric vehicles) or battery-powered (lawnmowers, wheelchairs, etc.) In order to assess their safety prior to first shipment, primary and lithium-ion cell and battery types need to be tested, whatever their size and their aggregated lithium metal or lithium-equivalent content. Note: At the time of writing these FAQ, the aggregated lithium-equivalent of a lithium-ion battery is defined as 0.3 times the declared nominal capacity of the component cells, multiplied by their number. For instance, a battery pack assembled from four 2.2 Ah cells, has to be declared with 0.3 x 2.2 x 4 = 2.64 grams of equivalent-lithium. Importantly, note the fact that a given cell type has been tested does not relieve the shipper from testing a battery or a battery pack assembled from such component cells. The UN Manual of Tests and Criteria lists 8 types of tests (T1 to T8*) to be applied to undischarged and fully discharged primary and rechargeable cell/battery samples, (in addition, and, samples cycled 1 or 50 times bee). Primary lithium cells with not more than 1 gram of lithium metal content, Rechargeable lithium-ion cells with not more than 1.5 gram of lithium-equivalent metal content, Primary lithium with not more than 2 grams of lithium metal content, Rechargeable lithium-ion with not more than 8 grams of lithium-equivalent metal content, that pass successfully the UN tests are exempted from regulations. They are declared non-restricted to transport or excepted from requirements (these two expressions are equivalent), something which is often abbreviated as non- assigned. Products with lithium contents exceeding the above limits and that also successfully pass the UN tests can just be declared restricted to transport or assigned to. Products that fail any of the UN transport tests can be transported by special authorization only, a cumbersome process that involves specific discussions with the local authorities in charge of transport in the country of origin of the shipment. Notes: - A battery pack assembled from restricted to transport component cells becomes automatically restricted to transport, even if it stays below the above-listed Li content limit. (For instance, a battery pack assembled from three 6 Ah component cells, each with 6 x 0.3 = 1.8 g of equivalent-li (above the 1.5 g limit) is, even if its total equivalent -Li content: 1.8 x 3 = 5.4 g, is below the 8 gram limit). A piece of equipment that contains or battery packs becomes assigned to. - Starting 1 January 2009, UN Identification Numbers Li will be modified as follows: - UN 3090, primary (lithium metal) transported in bulk, - UN, primary (lithium metal) contained in equipment or packed with it, - UN 3480, (and polymer) transported in bulk, - UN 3481, (and polymer) contained in equipment or packed with it. - Starting 1 January 2009, the lithium-equivalent notion will be replaced by the nominal energy one. This later is obtained by multiplying the declared nominal capacity by the number of component cells by the declared nominal voltage. The limits assignment to will be set at 20 Watt-hours (cells) and 100 Watt-hours (). - The transport testing of cells and can be made by the cell makers and battery assemblers themselves, or by specialized laboratories. The Transport Certificates that are issued at the end of the process are based on an Honour System. No specific UN inspection team will verify their accuracy unless field problems eventually happen. Better then to have all the evidences of proper testing at hand, in order to avoid troubles and heavy penalties! * T1 : Altitude simulation T2 : Thermal test T3 : Vibration T4 : Shock T5 : External short circuit T6 : Impact T7 : Overcharge T8 : Forced discharge 3

4 6 What are the practical consequences of being declared restricted to transport Lithium and cells and? Their transport is still possible, even by (see 10). Some specific constraints, however, are applicable at the product design, packaging and levels. The main ones, in general common to all the transportation modes, are the following: - battery packs containing cells or series of cells connected in parallel, must be equipped with effective means as necessary to prevent dangerous reverse current flows (meaning diodes, fuses, etc. to implement, if reverse current flows are known to pose a threat to safety), - each cell and battery must incorporate a safety venting device or be designed to preclude a violent rupture under conditions normally experienced during transport, - each cell and battery must be equipped with an effective means of preventing external short circuits, - cells and must be packed to effectively prevent short circuits and to prevent movement which could lead to short circuits, - Except certain large-mat and cells and contained in equipment, cells and must be packed in outer packaging meeting the so-called Packing Group II permance standard, - packaging must comply with specific packing Instructions (Packing Instructions 903, most often) and must display specific Miscellaneous Dangerous Goods labelling with UN identification number, - a specific Shipper s declaration dangerous goods has to be filled out, - The gross mass of the package bulk shipment and the quantity of lithium contained in transported equipment should not exceed certain limits. These limits vary depending on mode of transportation. For sea and road transport in Europe (ADR) - the bulk shipment of non-restricted products is limited to 30 kg per packaging, - except certain large-mat, the bulk shipment of products should be made in steel drums or steel/wood/plastic/fiberboard boxes not exceeding 400 kg, - no limits are specified products (restricted or not) shipped with or in equipment. The dispositions are different and more complex air transport (see 10) and within the USA (see 11). Note: Some express delivery companies (like DHL) and a very few airlines (listed in the IATA Dangerous Goods Regulations) do not carry products. 7 Are there any constraints products that are declared non-restricted to transport? Except air transport (see 10) and transport in the USA (see 11) and with not more than four cells or two installed in equipment, all - must be able to withstand a 1.2 meter drop without damage to the cells or contain therein, - must not exceed a gross mass of 30 kg and must meet certain other requirements, - must bear a and be accompanied by documentation mentioning that lithium products are contained within, and indicating whether the products are lithium metal or lithium-ion, giving an emergency phone number and mandating that packaging damaged during transport be quarantined, inspected and repacked. (For more detailed inmation, see Special Provision 188 in the UN Model Regulations, the IMDG Code and ADR). 8 The shipment of pre-production prototypes According to IMO and ADR, no pre-shipment testing is required prototypes (which are not otherwise defined) but the items, assigned to, need individual packaging, with outer packaging made of metal, plastic or plywood/wood drum or box meeting the criteria Packing Group I packaging. No limits are assigned to the size or number of prototypes that can be shipped. Same IATA/ICAO, which just adds that there should not be more than 24 cells or 12 per packaging. In addition, the shipment (by cargo only) must be approved by the appropriate authority of the State of origin. In the USA (see 11), the shipment of individually packed un-tested prototypes is allowed, as long as their transport is made by motor vehicle only. 9 The shipment of short production runs not exceeding 100 cells or According to IMO and ADR, no pre-shipment testing is required but the items, assigned to, need individual packaging. For air transport, IATA/ICAO does not allow the above disposition, meaning that pre-shipment testing remains mandatory. Intermediate situation in the USA with short production runs exempted from testing as long as is not used, and that product (of the small type only; see definition in 11)are individually packed, with Group I outer packaging. 4

5 10 The specific case of air shipment As may be expected, the air transport regulations are far more restrictive than the others. The U.S. DOT bans cells and, when transported in bulk, to be carried as cargo aboard -carrying. Outside the USA, and in addition to the case of prototypes, short production runs and fully discharged primary with liquid cathode, already mentioned in 4, 8 and 9, there are many specific dispositions, some of which will become applicable in 2009 Primary Li cells and Packaging Weight Limitations Marking/Labeling Shipping Document Current Jan 1, 2009 Current Jan 1, 2009 Current Jan 1, 2009 All categories - Pre 1 st shipment testing according to the UN Manual - Protection against short circuits Non- in bulk in bulk Non- with equipment with equipment Non- in equipment in equipment - Packages to withstand 1.2 m drop without damage to - Inner packaging completely encloses cell/ - Packing Group II packagings - For, cells/batt. with non-combustible non-conductive cushioning material + intermediate/outer packaging made of rigid metal - Packages to withstand 1.2 m drop without damage to - Inner packaging completely encloses - Packing Group II packagings - For, with non-combustible non-conductive cushioning material + outer packaging made of rigid metal - Equipment provided with an effective means of preventing accidental activation during transport - Strong outer packaging - Waterproof or made waterproof strong outer packaging - Equipment secured against movement and to prevent accidental activation during transport 30 kg max. and cargo 3 cargo None pass. 2. and cargo 2. 3 cargo (larger qty large if OKed by local authority None, but in each package limited to the minimum number to power the equipment + 2 spares pass. 3 3 cargo cargo containing more than 24 cells or containing more than 24 cells or 12 packed with None None None None, but - No more than 12 g/500 g of Li metal per cell/battery in any piece of equipment - No more than 5 kg of Li battery per piece of equipment of Li metal per piece of equipment 3 cargo contained in New handling label required on all 3090 New handling label required on all Packed with New handling label except when package contains no more than 4 cells or 2 contained in containing more than 24 cells or 12 all shipments Air waybill Indicating that Li metal cell/ all shipments Air waybill Indicating that containing more than 24 cells Li metal or 12 cell/ all shipments None all shipments all shipments Air waybill Indicating that Li metal cell/ all shipments 5

6 cells and Packaging Weight Limitations Marking/Labeling Shipping Document Current Jan 1, 2009 Current Jan 1, 2009 Current Jan 1, 2009 All categories - Pre 1 st shipment testing according to the UN Manual - Protection against short circuits Non- in bulk - Packages to withstand 1.2 m drop without damage to - Inner packaging completely encloses 30 kg max. /cargo 10 kg max. /cargo containing more than 24 cells or 12 New handling label required on all -Watt.hr rating marked on the battery case containing more than 24 cells or 12 Air waybill Indicating that Li ion cell/ in bulk - Packing Group II packagings - For, with non-combustible non-conductive cushioning material + intermediate/outer packaging made of rigid/strong material 3 cargo 3 cargo (larger qty large if OKed by local authority all shipments all shipments Non- with equipment - Packages to withstand 1.2 m drop without damage to cells/batt - Inner packaging completely encloses None None, but in each package limited to the minimum number to power the equipment + 2 spares containing more than 24 cells or 12 New handling label required on all - Watt.hr rating marked on the battery case containing more than 24 cells or 12 Air waybill Indicating that cell/. with equipment - Packing Group II packagings - For, with cushioning material + outer packaging made of rigid/strong material pass. pass. 3 3 cargo cargo packed with packed with 3481 all shipments all shipments Non- in equipment - Equipment provided with an effective means of preventing accidental activation during transport - Strong outer packaging None None None New handling label except when package contains no more than 4 cells or 2 - Watt.hr rating marked on the battery case None except when no more than 4 cells or 2 In equipment - Waterproof or madewaterproof strong intermediate/outer packaging - Equipment secured against movement to prevent accidental activation during transport None, but - No more than 5 kg of Li battery per piece of equipment pass. 3 cargo contained in contained in 3481 all shipments all shipments In addition to fully-discharged primary cells with liquid cathode (see 4), IATA/ICAO bans from air transport Li that have been identified by the manufacturer as being defective safety reasons or that have been damaged, or that have the potential of producing a dangerous evolution of heat, fire or short circuit In all cases, any person preparing/offering non- transport must receive adequate instruction on the above requirements. Any person preparing/offering transport must receive full dangerous goods training. 6

7 11 The specific case of transportation within the USA The Pipeline and Hazardous Materials Safety Administration which, within the U.S. Department of Transportation (DOT), oversees the transport of dangerous goods, whatever their transportation mode (land, sea, air) in the USA has long been slow taking into accounts the changes relating to lithium adopted over the years at the UN level. A harmonization eft has been engaged but is not fully completed yet. What remains specific to the USA -3 sizes of cells and are defined, based on their lithium or equivalent-lithium content Primary cells cells Primary Small (not more than) 1 g Li 1.5 g equiv-li 2 g Li 8 g equiv-li Medium (between) 1 and 5 g Li 1.5 and 5 equiv-li 2 and 25 g Li 8 and 25 g equiv-li Large (more than) 5 g Li 5 g equiv-li 25 g Li 25 g equiv-li After positive testing according to the UN manual of Tests and Criteria - small primary/, in bulk or with/within equipment can be transported un-restricted (the requirement testing small cells and becomes mandatory after 1 October 2009 only) - medium primary/, with or within equipment can be transported non-restricted by motor vehicle or rail car. If transported by air, however, they become assigned to. - large primary/, in bulk or with/within equipment, are assigned to, whatever the transportation mode In addition to the above, primary cells and, when transported in bulk, cannot be transported as a cargo aboard a -carrying. Whatever the envisioned transportation mode, the outside of each package that contains small primary cells or bidden aboard must be marked PRIMARY LITHIUM (or LITHIUM METAL) BATTERIES FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT. The above requirement does not apply to containing not more than 5 kg (11 pounds) net weight of contained in or packed with equipment when the not more than the minimum number of necessary to power the equipment. The outside of each package that contains medium Li cells or, unless transported as materials, must be marked, also whatever the envisioned transportation mode, LITHIUM BATTERIES FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL. Except when packed with or contained in equipment, containing more than 24 small or medium primary cells or 12 small or medium primary must be marked that they contain Li and special procedures must be followed in the event that the package is damaged. They must not exceed 30 kilograms (66 pounds) gross weight, be capable of withstanding a 1.2 meter drop test in any orientation without release of contents or shifting of contents that would allow short-circuiting, and be accompanied by a document repeating the above mentioned. Equipment packed with or containing small or medium-size primary can be transported as cargo aboard, provided the do not exceed a net weight of 5 kg (11 pounds) and provided that the not more than the minimum number of necessary to power the equipment. When the products are assigned to, labels are required. If the are not permitted aboard, the Cargo Aircraft Only label is required. Inner of cells or or packed with equipment can be transported aboard, as long as the inner package containing the cells or does not exceed a gross weight of 5 kg. For cells or in equipment, the transport aboard is possible as long as the net weight of does not exceed 5 kg (11 pounds). Consumer electronic devices containing lithium or lithium-ion cells or, such as watches, calculating machines, cameras, cellular phones, lap-top computers, camcorders, etc. when carried by air s or crew personal use are permitted aboard in carry-on luggage, without the approval of the operator or pilot-in-command. They must be individually protected against short circuits. Spare the above devices are allowed aboard if they do not exceed 2 grams of lithium metal content ( primary products) and 8 grams of equivalent lithium content ( products). with equivalent Li content in the 8-25 gram range can be taken aboard, but their number is limited to 2 units No testing is required prototypes, as long as their transport is made by motor vehicle the purpose of testing. The cells or are transported as material and must be individually packaged in an inner packaging. (Note: this is applicable as soon as products enter the U.S. zone, meaning that, unless special authorization is granted by the DOT, prototypes can just reach the U.S. by boat or land). 7

8 Short production runs of no more than 100 small Li or cells or are also exempted from testing but can be transported by motor vehicle, rail car or vessel only (no ). The outer packaging, made of metal, plastic, plywood drum or metal plastic or wooden box) need to meet the criteria Packing Group I packaging. Each cell/battery must be individually packed Lithium cells and that are shipped disposal or recycling may be transported by motor vehicle only. 12 U.S. dispositions regarding the mailing of lithium By October 5 th 2007, the U.S. Postal Service has adopted the following final rules : - Small consumer-type primary lithium cells and (with less than 1 gram per cell and 2 g per battery of lithium metal content and which have been tested according to the UN Manual of Tests and Criteria) can be mailed in the original sealed packaging, within a firmly sealed package, separated and cushioned to prevent short circuit, movement and damage. They are bidden aboard and, must display, marked on the address Side : Surface Mail Only Primary Lithium Batteries Forbidden Transportation Aboard Passenger Aircraft. The mailpiece must not exceed 5 pounds. - small consumer-type primary lithium cells and installed in the equipment they operate can be mailed if the device is equipped with an effective means of preventing accidental activation. The outside of the package must be marked : Package Contains Primary Lithium Batteries. The mailpiece must not exceed 11 pounds. - small consumer-type primary cells and (with less than 1.5/8 gram of equivalent lithium content per cell/battery and which have been tested according to the UN Manual of Tests and Criteria) may be mailed in a firmly sealed package, separated and cushioned to prevent short circuit, movement and damage. The outer package must be strong with complete delivery and return address and must be marked Package Contains Lithium-ion Batteries No Lithium Metal. Such items may be mailed via surface or air transportation. Not more than 3 per mailpiece; - Damaged or recalled are prohibited from mailing, unless approved by the manager, Mailing Standards. To Saft s knowledge, no Postal Service other than the U.S. one has taken dispositions regarding the mailing of lithium cells and. 13 What is the status of Saft Lithium cells versus transport regulations? The following Saft cell types have been retested according to the UN Manual of Tests and Criteria and, based on their lithium metal or lithium-equivalent contents, have been assigned to the following transport categories : Table 2 Saft lithium products status versus transport regulations Individual cells non-assigned to LS 14250/14250C/14250W LS 14500/14500C/14500W LS LST 14250/14500/17330 LSG 14250/14500 LS LSX PS 30/31A G 04/06/32/36 LM 2032/2430/2450 LM 17130/22150 MP / IS VL Individual cells assigned to LS 26500/33600/33600C/33600LM LSH 14/20/ 20 HTS G 20/22/26/32/36/52/54/62 LO 26B/39B LO 25SX/26SX/35SX/40SX LO26SHX/29SHX/30SHX/39SHX/43SHX LO 26SXC LM 26500/26600/33600 MP /176065/176065HD VL 34570/37570 VL 45E VL 41M VL 7P 14 What must be done to comply with the transport regulations? Anyone who packs and presents primary lithium and lithium-ion cells and shipment must be trained and certified as required by the dangerous goods regulations. Similarly, anyone who packs and presents non-assigned to Li and cells and must be trained in the requirements of the applicable exception under which these products are to be shipped. It is the responsibility of those who ship a new cell or battery type (or one changed in a manner that could affect the results; the UN Manual of Tests and Criteria details how similarity rules may apply) to make sure that testing according to the UN Manual has been properly permed bee first transport. 8

9 Cell and battery transport testing can be permed by the one which manufactured the shipped product or by a subcontracted test laboratory. The outcome of the tests is an official statement about the transport category to which the tested product belongs. Note: The outside packaging itself has also to demonstrate its ability to withstand, when filled with a given load of -assigned cells or, dropping and piling up. This leads to getting, from authorized testing laboratories, appropriate approval certificates. Saft offers testing of specific lithium according to the UN Manual of Tests and Criteria. You may contact your local Saft representative to discuss sample size, testing procedure, scheduling and cost. Violations of transport regulations are subject to fines. 9