Lithium batteries are the hottest topic in hazmat transportation today and the Federal Aviation Administration is aggressively enforcing penalties against employers who incorrectly offer them for transport (up to $77,114 per violation). To make matters worse, the shipping regulations are notoriously convoluted and confusing, and since their inception, have been continually changing. This presentation provides an overview of the regulatory requirements and enforcement trends, including the April 1, 2016 ICAO/IATA revisions.

1. Shipping Lithium
Batteries by
Ground & Air

2. Meet Your Moderator

3. During This Webinar
 All lines will be muted – please communicate
via the questions pane in your webinar panel.
 There will be a Q&A session at the end of the
presentation – submit your question(s) anytime
throughout the webinar.
 Stick around to learn about in-person training
opportunities being offered.
 The presentation will be emailed to you
tomorrow.

4. Meet Your Presenter
Doug Graham, CHMM
Sr. EH&S Consultant &
External Training Manager
dgraham@triumvirate.com
Over 23 years training hazmat shippers.

5. Objective
Obtain an overview of the
requirements for offering lithium
batteries via ground and air
Review the April 1, 2016
ICAO/IATA Revisions

6. Why Regulated?
Due to their properties,
lithium batteries pose unique
risks during transport,
especially by air.

7. • 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?

8. • 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?

9. 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?

10. 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?

11. 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.

12. 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

13. Topics
1. Carriers, Modes of Transport, and Regulations
2. Battery Classification by Type and Size
3. Requirements Applicable to All Li Batteries

14. Topics
4. Overview of Regulatory Requirements
5. Overview of April 1 ICAO/IATA Revisions
6. Prototype, Damaged/Defective, and Waste Lithium
Batteries

15. 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

16. 1. Carriers, Modes of Transport,
and Applicable Regulations

17. 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

18. 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.

19. 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.

20. 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

21. UPS Ground
49 CFR
49 CFR
UPS HAZMAT
SHIPPING
GUIDELINES
CARRIER
RESTRICTIONS+
Regulatory Perspective- Ground
+
FREIGHT SERVICES

22. 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?

23. 2. Battery Classification
by Type and Size

24. Poll Question
How many devices do
you have onsite that use
Li batteries?
a) <10
b) 10-20
c) 20-50
d) 50+

25. A. What Type?
Lithium Ion
or
Lithium Metal?

26. 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 Metal
including lithium alloy
These are
typically
marked
“Lithium”

27. 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 Ion
including lithium polymer

28. Classification &
Shipping Descriptions
B. DOT & IATA

29. 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

30. Shipping Names & ID Numbers
List of Dangerous
Goods- DGR Sec. 4.2
Hazardous Materials
Table- 49 CFR 172.101

31. 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 batteries
2. UN3481 Lithium ion batteries contained in equipment
3. UN3481 Lithium ion batteries packed with equipment
4. UN3090 Lithium metal batteries
5. UN3091 Lithium metal batteries contained in equipment
6. 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

32. 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 batteries
2. UN3481 Lithium ion batteries contained in equipment
3. UN3481 Lithium ion batteries packed with equipment
4. UN3090 Lithium metal batteries
5. UN3091 Lithium metal batteries contained in equipment
6. UN3091 Lithium metal batteries packed with equipment

33. 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 batteries
2. UN3481 Lithium ion batteries contained in equipment
3. UN3481 Lithium ion batteries packed with equipment
4. UN3090 Lithium metal batteries
5. UN3091 Lithium metal batteries contained in equipment
6. UN3091 Lithium metal batteries packed with equipment

34. 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 batteries
2. UN3481 Lithium ion batteries contained in equipment
3. UN3481 Lithium ion batteries packed with equipment
4. UN3090 Lithium metal batteries
5. UN3091 Lithium metal batteries contained in equipment
6. UN3091 Lithium metal batteries packed with equipment

35. Lithium Ion- power rating
and Lithium Metal- grams of lithium
C. Sizing the Batteries

36. 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

37. 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

38. 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

39. Li-Ion Power Rating
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.
A good rule of thumb: Laptop batteries are typically
49 Wh or 58 Wh and contain either 3 or 6 cells

40. 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.

41. 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

42. 3. Requirements Applicable
to All Lithium Batteries

43. Quality Manufacturing
One 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.

44. 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

45. • 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

46. 4. Overview of Requirements
by Battery Type, Mode of
Transport and Operator

47. 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

48. 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.

49. 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:

50. 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.

51. 5. Overview of Major
ICAO/IATA Revisions
Effective April 1, 2016

52. 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

53. 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

54. Li-Ion
CAO Handling Label
Ref: 49 CFR 172.448
DGR Sec. 7.2.4.2
CAO
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..

55. Limiting & Separating UN3480, Sec II
“Lithium Ion Batteries” Consignments
Effective 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

56. 49 CFR 173.185(d)-(f)
6. Waste, Damaged/Defective,
and Prototype Lithium
Batteries

57. 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

58. 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

59. 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

60. 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)

61. 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)

62. 4-Hour Training in Woburn, MA

63. Thank You for
Attending!
Triumvirate can handle your disposal needs.
Call Us!
1-888-834-9697
www.triumvirate.com
Doug Graham:
dgraham@triumvirate.com
Contact: