In addition to changes documented in the IATA 2016 (57th Edition) DGR, and the anticipated 2017 changes outlined in Appendix H (“Impending Changes” to ICAO Technical Instructions), recent incidents with lithium batteries and lithium battery-powered small vehicles (e.g. “Solowheels”, hoverboards, mini-“Segway”, etc.) have caused regulators to re-examine changes and deadlines.
Specifically ICAO intends to require that, in 2016 (date to be confirmed, April 1 proposed):
- Lithium ion cells and batteries (UN3480, PI 965) must only be offered for transport when their “state of charge” (SoC) does not exceed 30 % of the rated capacity, as determined by the UN Manual of Tests & Criteria (Section I cells/batteries are only allowed to exceed 30% if the States of Origin & Operator approve in writing).
- Not more than 1 package prepared under Section II of PI 965 (UN3480) or PI 968 (UN3090) may be placed in an overpack
- Overpacks prepared as above must have both the lithium caution label and “overpack” mark visible.
- Packages prepared as above must be offered separately from other cargo and not be loaded into a unit load device (ULD) before being offered to the carrier.
These are interim measures while performance-based standards are developed for lithium batteries; and until changes to UN3481 andUN3091 (packed with/in equipment) take effect in 2017. Some or all of these interim measures may be retained in the future editions of the DGR.
As IATA DGR includes all ICAO requirements, there should be an IATA DGR amendment once the date has been finalized by the ICAO Council.
Hover Boards etc. … “You’re Going to See Some Serious …”
Incidents involving fires with batteries powering these vehicles have led organizations such as the US CPSC and PHMSA to issue safety alerts related to this aspect of the hazards associated with the units.
In many instances, both for vehicles and other incidents, fires are attributed to failure to meet design/manufacturing criteria.
IATA and other regulatory bodies require that shippers verify that the batteries powering these articles are meet the requirements of the UN Manual of Tests & Criteria protocols before they can be legally shipped (subject to government-approved exceptions for prototypes).
Clarification has also been provided by IATA on the proper classification of these vehicles and the need to consider the difference between UN3171 (Battery Powered Vehicles), UN3481 (Lithium ion batteries packed with/in equipment) and UN3480.
While the latter entries provide some exemption based on the Wh (PI965-967) rating of the batteries, UN3171 does not. Vehicles (“…self-propelled apparatus designed to carry one or persons or goods”) shipped under UN3171 (PI952) are subject to full documentation requirements (Shipper’s Declaration) and, unless SP 87 applies, full Class 9 marking/labelling.
A vehicle, shipped with its battery installed, is UN3171 (PI952).
If, however, the battery is removed from the vehicle and shipped in the same outer package (i.e. “with”), the package becomes UN3481 (PI966) and the potential for exemptions applies based on the Wh rating of the battery.
If one or more batteries are shipped in a separate package then these are classed as UN3480 (PI965) and potential Wh-based exemptions may apply.
(Note that wheelchair/mobility aids used by passengers are still covered by “Limitation” subsection 22.214.171.124.)
Keep watching for news on amendments as we march/segue (Hover/Segway?) into 2016.