Lithium ION Battery Phrase Confusion with HM-224I

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…

Lithium batteries by air

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…