Update on Dangerous Goods Transportation Regulations for Lithium metal cells and batteries January 2015 Some transportation regulations have recently been revised and will come into effect after Jan. 1, 2015. It is important for those involved in shipments of lithium metal cells and batteries to understand the changes to the regulations as explained here. Since the information here is a summary of the changes, please use the updated Dangerous Goods Regulations listed in Normative Reference to confirm the details. The major revisions for air transport of lithium cells and batteries (1) Lithium metal cells and batteries as cargo in 2015 Lithium metal cells and batteries transported as cargo will be restricted to Aircraft Only from 1 st January 2015. The prohibition on the carriage on passenger aircraft only applies to lithium metal cells and batteries when shipped by themselves (PI968 Section IA, IB and II). The prohibition does not apply to lithium metal cells and batteries packed with equipment (PI969) or contained in equipment (PI970). As a result, items a) and b) below are also required. a) Labeling Aircraft Only (CAO) on outer package The CAO label must be located on the same surface of the package near the lithium battery handling label, if the package dimensions are adequate. For example: For lithium metal cell or batteries classified under PI968 Section IB, each package must be labeled with a lithium battery handling label in addition to Class 9 hazard label and the CAO label. b) Recording Aircraft Only or CAO on air waybill For example: For lithium metal cell or batteries classified under PI968 Section II, the words lithium metal batteries, in compliance with Section II of PI968 and Aircraft Only or CAO must be place on the air waybill, when an air waybill is used. (2) Quantity limitations of lithium cells and batteries classified under Section IB Gross mass will change to net quantity for lithium metal cells and batteries (PI968 Section IB) (see Table 968 IB below). The package and transport documentation will require NET QUANTITY to be indicated. GROSS WEIGHT no longer needs to be indicated. As a result, the letter G no longer needs to be used. Table 968-IB Contents Net quantity per package Lithium metal cells and batteries Forbidden 2.5 kg A summary of the revised requirements is shown in the following table. 1
1. Air transportation for lithium metal cells and batteries (Packing Instruction 968) Maxell branded cells will be classified as indicated in the following table. Li content per cell Product name Applied Section not more than 0.3 g All of ML cells and coin type CR cells ER3S Section II ER18/50, ER17/50H, ER17/50, ER6, ER6C, ER17/33, more than 0.3 g but Section IB ER3 not more than 1 g (Section II: 8 cells) CR17450A, CR17450, CR17335A, CR17335 more than 1 g (No) Section IA Please contact us for the lithium content of batteries which consist of multiple-cells. 2
2. Air transport of lithium metal cells and batteries packed with equipment (Packing Instruction 969) (1) A quantity limitation has been added to Section II Package quantity (Section II) Contents Net quantity of lithium metal cells or batteries per package 5 kg 5 kg Note: The words lithium metal batteries, in compliance with Section II of PI969 must be placed on the air waybill, when an air waybill is used. (2) A quantity limitation has been added to Section I Package quantity (Section I) UN number and product name UN3091 Lithium metal cells and batteries packed with equipment 5 kg 35 kg 3. Air transport of lithium metal cells and batteries contained in equipment (Packing Instruction 970) (1) A quantity limitation has been added to Section II Package quantity (Section II) Contents Net quantity of lithium metal cells or batteries per package 5 kg 5 kg Note: The words lithium metal batteries, in compliance with Section II of PI970 must be placed on the air waybill, when an air waybill is used. (2) A quantity limitation has been added to Section I Package quantity (Section I) UN number and product name UN3091 Lithium metal cells and batteries contained in equipment 5 kg 35 kg 3
The major revisions for UN Model Regulations 18 th Revised Edition New special provisions have been added regarding (1) damaged or defective lithium cells and batteries and (2) lithium cells and batteries for disposal or recycling. And new packing instructions have also been added for these new special provisions. (1) Summary of SP376: Damaged or defective lithium metal cells and batteries Damaged or defective lithium metal cells and batteries must be shipped as Class 9 dangerous goods. Packages shall be marked DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES. Cells and batteries shall be packed in accordance with packing instructions P908 or LP904, as applicable. Damaged or defective cells and batteries may include, but are not limited to: - Cells or batteries identified as being defective for safety reasons; - Cells or batteries that have leaked or vented; - Cells or batteries that cannot be diagnosed prior to transport; or - Cells or batteries that have sustained physical or mechanical damage. Cells and batteries liable to rapidly disassemble, dangerous react, produce a flame or a dangerous evolution of heat or a dangerous emission of toxic, corrosive or flammable gases or vapors under normal conditions of transport shall not be transported except under conditions specified by the competent authority. (2) Summary of SP377: Disposal or recycling of lithium metal cells and batteries Lithium metal cells and batteries for disposal or recycling must be shipped as Class 9 dangerous goods. Packages shall be marked LITHIUM BATTERIES FOR DISPOSAL or LITHIUM BATTERIES FOR RECYCLING. Cells and batteries shall be packed in accordance with packing instructions P909. Identified damaged or defective cells and batteries for disposal or recycling shall be transported in accordance with special provision 376 and packaged in accordance with P908 or LP904, as applicable. The IMDG Code 2014 edition will contain the descriptions of these UN recommendations. The voluntary compliance date is 1 st January 2015. Compliance becomes mandatory on 1 st January 2016. In some districts, countries may establish their own special requirements, the shipper shall confirm with the forwarder in advance. Reference Except air transportation, the minimum requirements to transport lithium metal batteries as exempted from class 9 dangerous goods (non-restricted goods) are as follows; 1) Cells and batteries shall be manufactured under a quality management programme. 2) For a lithium metal or a lithium alloy cell, the lithium content must not be more than 1 g. For a lithium metal or lithium alloy battery, the aggregate lithium content must not be more than 2 g. 3) Each cell or battery must be of the type proven to meet the requirements of each test in the UN 4
Manual of Tests and Criteria, 5th revised edition, Part III, sub-section 38.3. 4) Cells shall be packed in inner packagings that completely enclose the cell. The inner packagings shall be packed in strong outer packagings. 5) A battery handling label must be displayed on each package or Each package shall be marked with the following: the package contains lithium metal cells or batteries; the package must be handled with care and that a flammability hazard exists if the package is damaged; special procedures should be followed in the event that the package is damaged, to include inspection and repackaging if necessary; and a telephone number for additional information. 6) Each consignment must be accompanied by a document for transport with an indication that: the package contains lithium metal cells or batteries; the package must be handled with care and that a flammability hazard exists if the package is damaged; special procedures should be followed in the event that the package is damaged, to include inspection and repackaging if necessary; and a telephone number for additional information. 7) Each package must be capable of withstanding a 1.2 m drop test. 8) Except when batteries are installed in or packed with equipment, packages shall not exceed 30 kg gross mass Maxell will provide certificates for 2) and 3) as the need arises. Documentation for 4), 5) and 6) needs to be prepared by the customer. If our package is used for transport Maxell will provide the certificate for 7) as the need arises. However, if the customer s package is used, the customer must confirm the package can withstand a 1.2 m drop test. Furthermore, even if our package is used for transport, the telephone number printed on the package must be changed to that of the sender (customer). 5
Normative References Major applicable regulations for the transportation of lithium metal cells and batteries are as follows: UN (United Nations) Recommendations (Air, Marine, Overland transportation) UN (United Nations): Recommendations on the Transport of Dangerous Goods: Model Regulations 18th revised edition UN (United Nations): Recommendations on the Transport of Dangerous Goods: Manual of Tests and Criteria 5th revised edition Amendment 2 Air Transportation ICAO (International Civil Aviation Organization): Technical Instructions for the Safety Transport of Dangerous Goods by Air 2015-2016 Edition IATA (International Air Transport Association): Dangerous Goods Regulations 56th Edition, Effective 1 January 2015 Marine Transportation IMO (International Maritime Organization): International Maritime Dangerous Goods (IMDG) Code 2012 Edition (This is applicable until 31, December 2015) IMO (International Maritime Organization): International Maritime Dangerous Goods (IMDG) Code 2014 Edition (This is applicable on and after 1, January 2015 and will be mandatory on and after 1 January 2016) 6