Lithium Battery Shipping Requirements: Mark S. Koch (FTN Associates) Arkansas Environmental Federal Convention Virtual Presentation

Mark S. Koch undertook a virtual presentation at the Arkansas Environmental Federation Convention titled:

Lithium Battery Shipping Requirements (“Presentation”)

Mark serves as a Project Manager at FTN Associates, Ltd.

The term “lithium battery” denotes a family of batteries that have different chemistries. They are generally separated into two types of battery for hazardous material purposes which include:

• Lithium metal
• Lithium-ion

Lithium batteries are generally the preferred power source for a variety of consumer and portable electronic devices.

Lithium batteries are regulated as a hazardous material under the United States Department of Transportation’s (“DOT”) Hazardous Materials Regulations. See 49 C.F.R. Parts 171-180. The Hazardous Materials Regulations apply to any material DOT determines can pose an unreasonable risk to health, safety and property when transported in commerce. As a result, lithium batteries must conform to all applicable Hazardous Material Regulations requirement when offered for transportation or transported by air, highway, rail, or water.

Mark’s Presentation identified the following causes for concern in addressing lithium batteries:

• Used in various electronic devices and, therefore, are prevalent
• The two types – Lithium Metal and Lithium Ion
• Portable electronics we have would not exist without energy-dense, lithium-based batteries
• While most lithium batteries are safe, some have overheated and caught fire
• Constructed in layers
• Puncturing layers and exposure to air may cause reactions resulting in thermal runaway and fires
• Counterfeit and no-brand lithium batteries may not have been safety-tested

Mark also notes:

• Important to verify the batteries planned for shipment have been safety-tested
• Reference to the UN Manual Tests for lithium batteries
• Batteries that have not passed safety testing, Low-production and prototype batteries have specific requirements for shipping found in 49 CFR Part 173.185
• Different regulations apply depending on mode of shipping

Shipping considerations identified include:

• Lithium batteries are regulated based on the rated watt-hours for lithium ion batteries or the weight of the lithium contained in the batteries for lithium metal batteries (See M/SDS sheet)
• Certain types of battery shipments are prohibited or may require special arrangements
• Small and medium-sized lithium cells can be shipped as partially regulated in the 48 contiguous states by highway or rail if stricter packaging and marking requirements are met

The Presentation included a more detailed discussion of the small and medium size exceptions.

In terms of shipping considerations, major risks identified included:

• Short-circuit of the battery as a result of the battery terminals coming into contact with other batteries, metal objects, or conductive surfaces
• Puncture or damage to cells
• Handling mark must include the appropriate UN Identification number
• Special marking for medium-sized lithium batteries (detailed in the slide Presentation)

The Presentation included a detailed discussion of the small and medium lithium ion batteries and FedEx ground shipping in the 48 contiguous states.

The “major regulations” identified as potentially applicable to these batteries include:

• IATA – Dangerous Goods Regulations
• ICAO – Technical Instructions for the Safe Transport of Dangerous Goods by Air
• DOT – Hazardous Materials Regulations
• IMDG – Dangerous Goods Code

Recommendations identified by Mark include:

• When shipping, know your equipment
  • Lithium Ion or Lithium Metal
  • Enclosed or Separate
  • Battery Size -Determines which rules/exemptions apply
• Seek training
  • Lots of good haz mat shipping training our there both online and in person
• Contact your shipping company
  • They have resources to help

A copy of the slides can be downloaded here.