Shipping Lithium

Batteries by

Ground & Air

Meet Your Moderator

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Meet Your Presenter

Doug Graham, CHMM

Sr. EH&S Consultant &

External Training Manager

dgraham@triumvirate.com

Over 23 years training hazmat shippers.

Objective

Obtain an overview of the

requirements for offering lithium

batteries via ground and air

Review the April 1, 2016

ICAO/IATA Revisions

Why Regulated?

Due to their properties,

lithium batteries pose unique

risks during transport,

especially by air.

• High energy density can cause dramatic arcing in the event of an

external or internal short-circuit, which could lead to a fire.

• Defective batteries or accidental activation of equipment may

cause overheating, potentially leading to a fire.

• Individual cells within a battery pack may chain react in the event

of a fire.

• Fire may be difficult to extinguish (especially lithium metal)-

traditional fire extinguishing media (Halon) may not extinguish a

metal fire.

Properties

Why Regulated?

• Lithium metal batteries if damaged can cause spontaneous

fires from lithium exposure to the moisture in the air.

• Lithium metal batteries often contain chemical electrolyte that

creates toxic and/or corrosive vapor when exposed to air-

these can be released if the battery is damaged.

• The temperature of a lithium metal fire exceeds the melting

point of aluminium (the material of which most aircraft is

composed).

Properties (continued)

Why Regulated?

UPS flight 1307, a McDonnell Douglas DC-8-71F, N748UP, landed at its

destination airport, Philadelphia Pennsylvania, after a cargo smoke

indication in the cockpit. The flight crewmembers sustained minor

injuries, and the airplane and most of the cargo were destroyed by fire

after landing. The safety issues discussed in the NTSB report included

transport of lithium batteries on board aircraft.

History- UPS Flight Lands On Fire- Feb 7, 2006

Why Regulated?

A large fire developed in palletized cargo on the main deck at or near

pallet positions 4 or 5, in Fire Zone 3, consisting of consignments of

mixed cargo including a significant number of lithium type batteries and

other combustible materials. The fire escalated rapidly into a

catastrophic uncontained fire. The crew were killed in the crash.

History- UPS Flight Crashes Over Dubai- Sept 3, 2010

Why Regulated?

Enforcement

Lithium batteries are the

hottest topic in hazmat

enforcement today.

Violators of the hazardous-materials regulations can be

fined up to $75,000 per civil violation ($175,000 if an

injury results), and there are usually multiple violations

in any one case.

Air shipments attract the most scrutiny, go through a

screening process, and account for the highest

penalties for non-compliance.

FAA Inspections at Shipper’s Facility

Enforcement Trends

Incident- Driven

• Discovery of Non-Compliant Shipments

En-Route

• Discovery of Damaged or Leaking

Packages En-Route

Random & Unannounced

• Selecting Declarations at Operator (e.g.,

FedEx) Offices

• Discovery of Highly Hazardous Materials

En-Route

Topics

1. Carriers, Modes of Transport, and Regulations

2. Battery Classification by Type and Size

3. Requirements Applicable to All Li Batteries

Topics

4. Overview of Regulatory Requirements

5. Overview of April 1 ICAO/IATA Revisions

6. Prototype, Damaged/Defective, and Waste Lithium Batteries

Poll Question

How are you currently

disposing of lithium

batteries?a) Trash

b) Recycle with other batteries

c) Recycle separately

d) We don’t generate this type of waste

1. Carriers, Modes of Transport,

and Applicable Regulations

49 CFR HMR ICAO Tech. Instr.

In the 49 CFR, DOT references the use of the International Civil

Aviation Organization (ICAO) technical instructions to be followed for

international air shipments.

Regulatory Perspective- Air

49 CFR HMR ICAO Tech. Instr. IATA DGR

Regulatory Perspective- Air

The majority of the commercial air carriers (e.g., FedEx Express)

follow the International Air Transport Association (IATA) Dangerous

Goods Regulations (DGR) by policy for both domestic and

international. Therefore, all offerors must prepare the

shipment in accordance with the IATA DGR.

Regulatory Perspective- Air

IATA DGR

All FedEx Express shipments (domestic or int’l) must be IATA- prepared.

All international shipments regardless of operator are also IATA-prepared.

Regulatory Perspective- Air

UPS HAZMAT

SHIPPING GUIDE

UPS ® domestic services that have

the potential to travel by air include:

UPS Next Day Air ®, UPS 2nd Day

Air ®, and UPS Express Critical ®

For UPS Domestic Air

Service, both the 49 CFR and

the UPS Hazmat Shipping

Guide must be followed.

Some lithium ion and lithium metal battery

shipments required a UPS Dangerous Goods

Contract- see UPS Fact Sheet- “U.S. Lithium

Battery Regulations”- rev 2/6/15

UPS Ground

49 CFR

49 CFR

UPS HAZMAT

SHIPPING

GUIDELINES

CARRIER

RESTRICTIONS+

Regulatory Perspective- Ground

+

FREIGHT SERVICES

So, determining the carrier and

the mode of transport makes a

huge difference.

Decide upon the carrier(a hazmat contract or pre-approval may be

required for certain Li batteries)

Decide upon air vs. ground(always chose ground if possible)

International or domestic?

2. Battery Classification

by Type and Size

Poll Question

How many devices do

you have onsite that use

Li batteries?a) <10

b) 10-20

c) 20-50

d) 50+

A. What Type?

Lithium Ion

or

Lithium Metal?

Lithium metal batteries are most commonly primary (non-rechargeable)

batteries that have lithium metal as an anode. They are often used to

power devices such as watches, calculators, cameras, temperature data

loggers, medical devices, remote monitoring equipment, and a wide

variety of industrial and military equipment.

Lithium Metalincluding lithium alloy

These are

typically

marked

“Lithium”

Lithium ion batteries are secondary (rechargeable) batteries

most commonly associated with consumer electronics, such

as laptop computers and mobile phones, but have a very

wide variety of applications from industrial, military, scientific,

and automotive. These are typically

marked

“Lithium Ion”

“Li-Ion”

“Lithium Polymer”

“Li-Polymer”

Lithium Ionincluding lithium polymer

Classification &

Shipping Descriptions

B. DOT & IATA

Because the risks posed by lithium batteries during

transport are unique and do not fall under hazard

Classes 1-8, they have been assigned to-

Class 9- Miscellaneous

Hazard Classification

Shipping Names & ID Numbers

List of Dangerous

Goods- DGR Sec. 4.2

Hazardous Materials

Table- 49 CFR 172.101

There are six possible shipping names with corresponding ID numbers for lithium battery shipments selected based upon the type and how the

package is configured:

1. UN3480 Lithium ion batteries2. UN3481 Lithium ion batteries contained in equipment3. UN3481 Lithium ion batteries packed with equipment

4. UN3090 Lithium metal batteries5. UN3091 Lithium metal batteries contained in equipment6. UN3091 Lithium metal batteries packed with equipment

Note: Vehicles only powered by lithium metal or

lithium ion batteries are consigned under the

entry UN3171, Battery-powered vehicle.

Shipping Names & ID Numbers

Shipping Names & ID Numbers

There are six possible shipping names with corresponding ID numbers for lithium battery shipments selected based upon the type and how the

package is configured:

1. UN3480 Lithium ion batteries2. UN3481 Lithium ion batteries contained in equipment3. UN3481 Lithium ion batteries packed with equipment

4. UN3090 Lithium metal batteries5. UN3091 Lithium metal batteries contained in equipment6. UN3091 Lithium metal batteries packed with equipment

Shipping Names & ID Numbers

There are six possible shipping names with corresponding ID numbers for lithium battery shipments selected based upon the type and how the

package is configured:

1. UN3480 Lithium ion batteries2. UN3481 Lithium ion batteries contained in equipment3. UN3481 Lithium ion batteries packed with equipment

4. UN3090 Lithium metal batteries5. UN3091 Lithium metal batteries contained in equipment6. UN3091 Lithium metal batteries packed with equipment

Shipping Names & ID Numbers

There are six possible shipping names with corresponding ID numbers for lithium battery shipments selected based upon the type and how the

package is configured:

1. UN3480 Lithium ion batteries2. UN3481 Lithium ion batteries contained in equipment3. UN3481 Lithium ion batteries packed with equipment

4. UN3090 Lithium metal batteries5. UN3091 Lithium metal batteries contained in equipment6. UN3091 Lithium metal batteries packed with equipment

Lithium Ion- power rating

and Lithium Metal- grams of lithium

C. Sizing the Batteries

Lithium ion batteries are sized by power rating in Watt-hours

(Wh) per cell and Watt-hours per battery. Manufacturers

have been recently required to mark the power in Wh on the

battery.

Li-Ion Power Rating

49 Watt-hours

Li-Ion Power Rating

49 Watt-hours

Battery packs are made up of individual cells, (often AAA, AA, or C- sized

cells) connected together and encased in a rigid plastic case. If the

battery shown below is made up of eight individual cells, then each cell

has a 6.125 Wh rating (49 ÷ 8).

49 Watt-hours ÷ 8 cells = 6.125 Wh per cell

Batteries older than more than a few years may only have the

Voltage and Amp-hour ratings marked. To calculate the Wh rating,

since Volts x Amps = Watts, simply multiply the two.

11.1 Volts x 4.4 Ah (4400mAh) = 50 Wh

Li-Ion Power Rating

Li-Ion Power RatingBatteries older than more than a few years may only have the

Voltage and Amp-hour ratings marked. To calculate the Wh

rating, since Volts x Amps = Watts, simply multiply the two.

A good rule of thumb: Laptop batteries are typically

49 Wh or 58 Wh and contain either 3 or 6 cells

The lithium content in grams per cell and grams per battery is

used to categorize lithium metal batteries by size.

Li-Metal Sizing

(Grams of Lithium)

Unfortunately, the manufacturers typically only

mark the voltage on the battery, not the lithium

content.

Li-Metal Sizing

(Grams of Lithium)The manufacturer may need to be contacted to

make this determination

A good rule of

thumb: AA-size

batteries typically

contain slightly less

than 1 gram of

lithium

3. Requirements Applicable

to All Lithium Batteries

Quality ManufacturingOne of the greatest risks related to lithium batteries

is a poorly manufactured battery overheating or

internally short circuiting and

causing a fire.No hover-board for

the kids this year…

check.

DOT and IATA require that :

Only cells and batteries manufactured under a quality

management program may be offered for transport. The

following elements must be included in such a program:

• Each cell/battery is of the type proved to meet

the testing requirements of UN Manual of Tests

& Criteria, Part III, Subsection 38.3;

• A safety venting device is incorporated into the

design of each cell/battery;

Quality Manufacturing

Ref: 49 CFR 173.185(a)

IATA DGR Sec. 3.9.2.6

• Each cell/battery is equipped with an

effective means of preventing external short

circuits;

• Batteries containing cells connected in

parallel be equipped with a means to prevent

reverse current flow; and

• The quality management program have

specific elements.

Quality Manufacturing

Ref: 49 CFR 173.185(a)

IATA DGR Sec. 3.9.2.6

4. Overview of Requirements

by Battery Type, Mode of

Transport and Operator

For ground shipping, follow the applicable requirements of the current edition of

the DOT hazardous materials regulations (HMR) in 49 CFR 100-185.

Fully-regulated batteries must follow all the requirements of the HMR in addition

to any additional requirements in the referenced Special Provisions and the

Packaging Authorization (173.185).

Smaller batteries need only follow the requirements in 173.185(c).

Ground Transport

Smaller batteries (partially exempt) are defined as-

For Lithium Ion, each cell < 20 Wh, battery <100 Wh

For Lithium metal, each cell < 1g net Li, battery < 2g net Li

For air shipping, follow the applicable requirements of the current edition of the IATA

Dangerous Goods Regulations (DGR).

Fully-regulated batteries (“Section I batteries”) must follow all the requirements of the

DGR in addition to any additional requirements in the referenced Special Provisions

and the Packing Instruction (PI 965-970, as applicable).

Smaller batteries (“Section II batteries”) need only follow the requirements in the

applicable Packing Instruction.

Air Transport

Note: UPS Domestic Air shipments may be prepared in accordance

with the HMR and the UPS Hazmat Shipping Guide.

It’s important to also look into the additional requirements and restrictions

imposed by the various operators, many of which address lithium battery

shipments. Two significant examples:

Operator Approval & Variations

If offered to FedEx Express, all lithium metal batteries without

equipment (UN3090) under IATA Packing Instruction 968, Sections

IA and IB (and Sec. II, according to FX-07), require pre-approval.

Effective July 1, 2015, only pre-approved customers are allowed to

ship lithium metal batteries without equipment (UN3090) via UPS®

Air services. Learn more about pre-approval:

The devil’s in the details- the specific

requirements for any given lithium battery

shipment may vary significantly based upon

battery type, size, shipping name, quantity,

configuration, weight, transporter,

destination, and mode of transportation.

Specific SOPs

If this were an actual training session, this portion of the presentation would include 140

additional slides and an additional 3 ½ hours of lecture to cover all the possible DOT,

IATA, and Operator requirements applicable to any possible shipment.

5. Overview of Major

ICAO/IATA Revisions

Effective April 1, 2016

Note: Under the new Special Provision A201 Individual countries may grant an

exemption from this prohibition (with conditions).

ICAO Safety Advisory- April 1, 2016

Ref: DGR PI 965

ICAO/IATA Li-Ion

Passenger Air Restriction

Effective April 1, 2016, ICAO/IATA prohibits transporting all

UN3480 lithium ion batteries (Sec. IA, IB, and III) as cargo aboard

passenger carrying aircraft (prohibition is not applicable to

batteries packed with, or contained in equipment).

Li-IonRef: DGR PI 965

Note: Guidance and methodology for determining the rated capacity can be found in

Sec. 38.3.2.3 of the UN Manual of Tests and Criteria, 5th revised edition, Amend. 1

Additionally, effective April 1, 2016, all UN3480 lithium ion cells

and batteries (Sec. IA, IB, and Sec. II) must be offered at a state of

charge (SoC) not exceeding 30% of their rated design capacity.

Ref: DGR PI 965 Li-Ion

ICAO Safety Advisory- April 1, 2016

Ref: DGR PI 965

ICAO/IATA Li-Ion

Passenger Air Restriction

Li-Ion

CAO Handling Label

Ref: 49 CFR 172.448

DGR Sec. 7.2.4.2CAO

Effective April 1, 2016, the

“Cargo Aircraft Only” label must

also be used when offering

UN3480, Sec. II batteries.

The lithium battery handling label must appear

near and on the same surface of the package

as the CAO label..

Limiting & Separating UN3480, Sec II

“Lithium Ion Batteries” ConsignmentsEffective April 1, 2016, a shipper is not permitted to offer for transport more than one (1) package of

UN3480 (batteries packed alone) prepared in accordance with PI 965, Sec. II in any single

consignment.

Additionally, such packages must be offered to the operator separately from cargo which is not subject

to the instructions.

Ref: DGR PI 965, Sec. II Li-Ion

49 CFR 173.185(d)-(f)

6. Waste, Damaged/Defective,

and Prototype Lithium

Batteries

A lithium cell or battery, including a lithium

cell or battery contained in equipment, that

is transported by motor vehicle to a

permitted storage facility or disposal site,

or for purposes of recycling, is excepted

from:

• Testing and recordkeeping requirements

• UN-Specification packaging when in strong outer

packaging

Waste Lithium Batteries

Waste Lithium Batteries

A lithium cell or battery that meets the size,

packaging, and hazard communication

conditions in paragraph 173.185(c)(1)-(3)

is excepted from:

Ref: 49 CFR 173.185(d)

Shipping Papers

Marking

Hazard Labeling

Handling Labeling

Placarding

Emergency Response Information

Training

UN- Specification Packaging

Low production runs (i.e., annual

production runs consisting of not more

than 100 lithium cells or batteries), or

prototype lithium cells or batteries

transported for purposes of testing, are

excepted from the testing and record

keeping requirements provided the

shipment is approved by the DOT and

comply with 49 CFR 173.185(e) and if

an IATA shipment, comply with Special

Provision A88.

Prototype Lithium Batteries

Li-MetalLi-Ion

Lithium cells or batteries, that have been

damaged or identified by the manufacturer

as being defective for safety reasons, that

have the potential of producing a

dangerous evolution of heat, fire, or short

circuit (e.g., those being returned to the

manufacturer for safety reasons) may be

transported by highway, rail or vessel only.

Damaged/Defective Lithium Batteries

Ref: 49 CFR 173.185(f)

Damaged/Defective Lithium Batteries• Each cell or battery must be placed in individual, non-metallic

inner packaging that completely encloses the cell or battery;

• The inner packaging must be surrounded by cushioning material

that is non-combustible, non-conductive, and absorbent; and

• Each inner packaging must be individually placed in a UN-

Specification packaging at the Packing Group I level- see

185(f)(3) for specifics.:

• The outer package must be marked with an indication that the

package contains a “Damaged/defective lithium ion battery”

and/or “Damaged/defective lithium metal battery” as appropriate.

IATA Special Provision A154 makes these batteries

FORBIDDEN for transport aboard aircraft.

Ref: 49 CFR 173.185(f)

4-Hour Training in Woburn, MA

Thank You for

Attending!Triumvirate can handle your disposal needs.

Call Us!1-888-834-9697www.triumvirate.com

Doug Graham:

dgraham@triumvirate.com

Contact: