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Shipping Lithium Batteries by Ground and Air

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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.

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Shipping Lithium Batteries by Ground and Air

  1. 1. Shipping Lithium Batteries by Ground & Air
  2. 2. Meet Your Moderator
  3. 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. 4. Meet Your Presenter Doug Graham, CHMM Sr. EH&S Consultant & External Training Manager dgraham@triumvirate.com Over 23 years training hazmat shippers.
  5. 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. 6. Why Regulated? Due to their properties, lithium batteries pose unique risks during transport, especially by air.
  7. 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. 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. 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. 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. 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. 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. 13. Topics 1. Carriers, Modes of Transport, and Regulations 2. Battery Classification by Type and Size 3. Requirements Applicable to All Li Batteries
  14. 14. Topics 4. Overview of Regulatory Requirements 5. Overview of April 1 ICAO/IATA Revisions 6. Prototype, Damaged/Defective, and Waste Lithium Batteries
  15. 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. 16. 1. Carriers, Modes of Transport, and Applicable Regulations
  17. 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. 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. 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. 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. 21. UPS Ground 49 CFR 49 CFR UPS HAZMAT SHIPPING GUIDELINES CARRIER RESTRICTIONS+ Regulatory Perspective- Ground + FREIGHT SERVICES
  22. 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. 23. 2. Battery Classification by Type and Size
  24. 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. 25. A. What Type? Lithium Ion or Lithium Metal?
  26. 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. 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. 28. Classification & Shipping Descriptions B. DOT & IATA
  29. 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. 30. Shipping Names & ID Numbers List of Dangerous Goods- DGR Sec. 4.2 Hazardous Materials Table- 49 CFR 172.101
  31. 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. 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. 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. 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. 35. Lithium Ion- power rating and Lithium Metal- grams of lithium C. Sizing the Batteries
  36. 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. 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. 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. 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. 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. 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. 42. 3. Requirements Applicable to All Lithium Batteries
  43. 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. 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. 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. 46. 4. Overview of Requirements by Battery Type, Mode of Transport and Operator
  47. 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. 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. 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. 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. 51. 5. Overview of Major ICAO/IATA Revisions Effective April 1, 2016
  52. 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. 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. 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. 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. 56. 49 CFR 173.185(d)-(f) 6. Waste, Damaged/Defective, and Prototype Lithium Batteries
  57. 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. 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. 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. 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. 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. 62. 4-Hour Training in Woburn, MA
  63. 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:

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