Welcome to the ever-changing world of transporting lithium batteries. It feels like just yesterday we were discussing the introduction of the new Class 9 hazard label dedicated to just batteries and the new handling “mark”. Would you believe that started at the end of 2016? In an attempt to clarify things, here is the first of several blogs dedicated to one of the new versions of a transport regulation. The focus will be what changed in regards to lithium batteries for that mode. My first choice, only because it is my favorite regulation, is the 60th edition of the International Air Transport Association or IATA as many of us know it. By the way, ICC will be hosting a training on lithium batteries on January 24th and 25th. Call us today to get registered today.
Listed below are the specific sections, paragraphs, packing instructions and the like that had changes for lithium cells and batteries. If you aren’t overly familiar with shipping batteries, what is below can be a bit overwhelming. You can access our “cheat sheet” for required labels by ground, ocean, and air.
IATA 60th Edition Changes for Batteries:
- New classification criteria – As part of 184.108.40.206.1 there are 2 new paragraphs around the classification of lithium batteries. One paragraph talks about “hybrid” batteries, which are those that contain both ion and metal while the other is about Section 38.3 Test reports.
- Revisions to existing Special Provisions – The following Special Provisions have revisions to them – A88, A201, and A206.
- New special provisions – There are 2 new Special Provisions as well. One is A213 and the other is A334. The A213 provision centers around the “hybrid” batteries. Under A334 there is an allowance for batteries to be transported on passenger planes as long as a long list of conditions is met including authority of the state of origin, state of destination and state of the operator.
- IATA guidance document reference – There is embedded within each packing instruction a link to the lithium battery guidance document. The document is currently based on the 58th edition, but work is being done to reflect the changes brought in by the 60th.
- Packing instruction revisions – Packing Instruction 965, 966, 968 and 969 paragraph (c) under General Requirements now has a clarification regarding “protection against contact with ELECTRICALLY conductive materials within the same packaging….”
- Packing instructions and overpacks – Overpacks of Section II cells and batteries when the marks and labels representative of those on the package inside are not visible, the word “overpack” must be marked on the outside in letters that are at least 12 mm high. This height requirement is actually true for any overpack in IATA.
- Spare battery clarification – In Packing Instructions 966 and 969, you cannot exceed the number required for the operation of the equipment plus “2 spare sets”. A set is now defined as the number of individual cells or batteries that are required to power each piece of equipment.
- Mark and label revisions – The only hazard class label and mark allowed to be used are Figures 7.3.X and Figure 7.1.C when applicable. For those cells and batteries that meet the criteria to be a Section 1B and II, the only mark allowed is the one in Figure 7.1.C. The old handling label is no longer available. Also, there is still the notation that the UN numbers on the mark “should” be 12 mm high. This is still not a mandatory requirement.
- Segregation Table 9.3.A and Paragraph 220.127.116.11.3 – The Note under the table has been corrected to reflect Class 9 materials are not on the table unless they are lithium batteries. Paragraph 18.104.22.168.3 has some adjustments made to it in an attempt to clarify the segregation requirements for packages and overpacks of UN3480 and UN3090 batteries meeting Section 1A and Section B criteria.
So, that’s it. That is a pretty comprehensive list of what changed for batteries for the new IATA that comes into force on January 1, 2019. For each bullet point, there is enough information for someone to track down the specifics if more information is needed. If you are a customer of ours and have questions on this, take advantage of our helpdesk feature and ask for the Regulatory Department. Don’t forget about that training being held in January. There will be more detail presented in that as well. Keep an eye out for the next blog, which will focus on the lithium battery changes in the 39-18 IMDG Code.