Every year when teaching the concept of density to high schoolers, I would use the story of Archimedes and the king’s crown. They really enjoyed the part of him running naked through the streets shouting, “Eureka, I have found it.” Since that time, the concept of “eureka moments” has become a thing. The moment you finally realize, understand, or discover something is a “eureka moment”.
My most recent one occurred while updating ICC’s lithium battery courses. You see, I’ve always struggled with a few paragraphs in 49CFR 173.185. The paragraphs in question are (c)(1)(iii) and (c)(1)(iv) for those smaller or “excepted” cells and batteries. My brain just couldn’t comprehend or truly understand what they were telling me. Add to that the changes brought in by the interim final rule HM-224I and my brain was just fried. Both paragraphs are shown below for your reference.
Except when lithium cells or batteries are packed with or contained in equipment in quantities not exceeding 5 kg net weight, the outer package that contains lithium cells or batteries must be appropriately marked: “PRIMARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”, “LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”, “LITHIUM ION BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT” or labeled with a “CARGO AIRCRAFT ONLY” label specified in §172.448 of this subchapter.
For transportation by highway or rail only, the lithium content of the cell Continue Reading…
Laurel and Hardy the comedy duo from the 1930’s coined the phrase, “Well, here’s another nice mess you’ve gotten me into.” Sadly, I believe this is the situation DOT created with HM-224I which is an interim final rule published in March. When this new rule is taken into account along with the general frustration many shippers face when shipping lithium batteries, it is easy to see how the mess was made.
Basically, here’s what happened. The 49 CFR can be used to make air shipments along with going by ground and vessel. In the “old” version of the regulations, you were allowed to put lithium ion batteries on passenger planes as long as the net weight of the batteries was below 5 kg. Well, DOT has finally admitted it is NOT a good idea to put lithium ion batteries on passenger aircraft. They also wanted to be in closer alignment with the IATA which restricted ion batteries to cargo planes just a few years ago. This is where HM-224I comes into play.
One of the biggest changes is the addition of a phrase to section 173.185 for small powered or excepted batteries. It is paragraph (c)(1)(iii) that is causing the most trouble. Keep in mind nothing changed with the existing phrases in this paragraph. It is simply a matter of a new one being added. Also, this paragraph Continue Reading…
Shipping lithium batteries has become a confusing issue. Let’s start by asking “what is a lithium battery?”. There are two types of lithium batteries – metal and ion (polymer). The lithium metal battery is also termed “primary” which means non-rechargeable. Typically you find these batteries in watches, calculators, cameras, etc. Lithium ion (and polymer) are “secondary” or rechargeable batteries. These are found in mobile phones, laptop computers, satellite navigation units, etc.
As most shippers are aware, ICAO/IATA rewrote the packing instructions for shipping lithium batteries by air for 2009. In the 51st Edition of the IATA Dangerous Goods Regulations for 2010, the packing instructions for lithium batteries have changed again.
First a quick review: the shipping name Lithium batteries is now either Lithium ion batteries or Lithium metal batteries. And for each of these shipping names are two (2) more: contained in equipment or packed with equipment. The shipping descriptions are:
- UN3090, Lithium metal batteries
- UN3091, Lithium metal batteries contained in equipment
- UN3091, Lithium metal batteries packed with equipment
- UN3480, Lithium ion batteries
- UN3481, Lithium ion batteries contained in equipment
- UN3481, Lithium ion batteries packed with equipment
The packing instructions in the 51st Edition of the IATA Dangerous Goods Regulations now consist of 3 sections. Packing instructions 965-970 each consist of:
- General Requirements: outlines the requirements for that battery type
- Section I: these batteries are fully regulated as Class Continue Reading…