Lithium Battery Segregation
It is January and all of the new or updated transport regulations are in full swing. This includes the new IATA addendums and IMDG Code corrigenda that were recently published. That leaves many tracking down what changed in and how those changes could impact business. Add to that dealing with the complexities that come with shipping lithium batteries and many people end up feeling confused like Vincent “Vinny” Barbarino on “Welcome Back Kotter”. Check out that memory.
Here is my attempt to simplify the placarding and segregation requirements as they now stand for lithium batteries. Let’s take a look at each topic and regulation to sort things out.
49 CFR – US Ground
Placarding (§172.504): Class 9 materials are found on Table 2. This indicates that when the gross aggregate weight of the materials in the transport vehicle reaches 1001 pounds (454 kilograms) placards would be needed. In Paragraph (f)(9) there is an exception. The exception tells us that placards are not needed for Class 9 materials shipped domestically. Easy right? Now this paragraph also tells us that should you use a bulk packaging of batteries, we would be required to mark the identification number on an orange panel, a white square-on-point configuration or a Class 9 placard.
Segregation and Separation Chart of Hazardous Materials (§177.848): There is currently nothing in this section of 49 CFR to indicate batteries should be segregated or separated from other hazardous materials.
59th Edition of IATA for Air
Placarding: There are no requirements to placard a plane in the IATA Dangerous Goods regulations. You must still follow any ground placarding rules that would apply to getting your shipment to and/or from the airport.
Segregation of Dangerous Goods (9.3.2): New this year is a change to Table 9.3.A Segregation of Packages and the addition of a new section. The new table, shown below now includes Class 9 materials but it directs you to read Section 184.108.40.206.3. That paragraph pertains to lithium batteries. Basically, if you have a lithium-ion battery that meets the criteria of being a Section 1A or Section 1B in Packing Instruction 965, then it must be segregated from other packages/overpacks of goods labeled as flammable or explosive. The same is true for lithium metal batteries and Packing Instruction 968. The paragraph explicitly lists goods in Class 1 Explosives (except Division 1.4S), Division 2.1 Flammable Gases, Class 3 Flammable Liquids, Division 4.1 Flammable Solids and Division 5.1 Oxidizers. Now the paragraph uses the word “must” which means this is a mandatory requirement. There is a note though that says these rules are not mandatory until 1/1/19 but operators should take steps to implement as soon as possible. If you are a shipper, per Section 220.127.116.11.1 those Section 1A or 1B batteries in Packing Instructions 965 and 968 are not permitted in overpacks at all with any explosives or flammables. A shipper should also review 18.104.22.168 paragraph (h) note 4. This tells a shipper that you are not allowed to package batteries meeting Section 1A or 1B in the same outer package as any explosive or flammable material.
38-16 IMDG for Vessel
Placarding (Chapter 5.3): The general rule for placarding within IMDG is “if there is a label on the package, then a placard is required”. So, if our packages of batteries are labeled with a Class 9 hazard label, we will need a placard. However, there is no new “lithium battery placard” that would be used in conjunction with the new Class 9 battery label. There is a new paragraph that tells you to use the normal Class 9 placard in this case.
Segregation (Chapter 7.2) and Stowage (Chapter 7.1): Segregation for IMDG is a bit complex. Not only do you have to pay attention to the segregation requirements but also to those for stowage and what is in the Dangerous Goods List (DGL). Luckily for lithium batteries of all types the information is the same. Let’s start with the information in the DGL. Column 16a for Stowage and Handling tells us to follow Category A and SW19. Category A tells us to stow the packages either “on deck” or “under deck,” but nothing about keeping them away from any certain goods. Column 16b for Segregation is blank, so that is easy. Column 17 says, “batteries may cause fire,” but nothing about any particular goods to avoid. After all of that, there is nothing in the IMDG Code that directly tells us to segregate lithium batteries from any other goods.
It is so much to take in and understand. Hopefully by listing things here as they are it will be easier to understand. No one needs to be “confused” any more. If you are, please contact ICC today for all of your battery questions, packaging and training needs.