• Alex Tan, CHMM

Shipping Lithium Batteries? PHMSA Published Final Rules Harmonizing International Standards


Effective on March 30, 2017, Pipeline and Hazardous Materials Administration (PHMSA) and Department of Transportation (DOT) published a final rule, HM-215N, amending Hazardous Materials Regulations (HMR) to harmonize recent changes made to the International Maritime Dangerous Goods Codes, the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air, and the United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations.


In concentration of the Transport of Lithium Cell or Battery, there are several key changes in labeling and marking.


Labeling

Lithium batteries are termed in Lithium ion and Lithium metal. Lithium ion batteries are rechargeable, and Lithium metals are not. Both are classified as Class 9 - Miscellaneous Dangerous Goods, and different conditions have been assigned into the Hazardous Material Table:

  • UN 3090 - Lithium metal batteries

  • UN 3091 - Lithium metal batteries contained in equipment

  • UN 3091 - Lithium metal batteries packed with equipment

  • UN 3480 - Lithium ion batteries

  • UN 3481 - Lithium ion batteries contained in equipment

  • UN 3481 - Lithium ion batteries with in equipment

If applicable, the new Class 9 hazard sign shall be used instead of the old Class 9 hazard sign. However, the transition period has been extended to December 31, 2018.

OLD NEW


On December 15, 2016, International Air Transport Association (IATA) published a 2017 Lithium Battery Guidance Document, which included a flow chart for both Lithium ion and Lithium metal batteries to better help shippers to understand the labeling criteria.


Marking



The old standard marking (top) has been changed to the new standard marking (bottom), and the transition period is the same as the labeling, which is until December 31, 2018. The phone number is still required, and the minimum dimensions remain the same as 120mm wide x 110mm high. In cases which the package is smaller, the minimum dimensions may be reduced to 105mm wide x 74mm high. In the new standard marking, * is for UN number(s) - UN3090, UN3091, UN3480, and/or UN3481, and ** is for the telephone number.

To comply with the UN Model Regulations, the mark, "Damaged/Defective Lithium Ion Batteries" and/or "Damaged/Defective Lithium Metal Batteries," now requires the characters to be at least 12mm high.


Additional Information

United EHS Consulting provides professional consultation services to all levels of employers. The author/consultant has several years of experiences in exposure assessment, program management, and injury prevention. For any inquiries, contact us through our website.


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