One of my favorite episodes of the show Seinfeld is the one where worlds collide. In the episode Elaine asks George’s girlfriend Susan to a show. On the surface this seems harmless. According to Kramer, this is a bad thing because when George’s “sanctuary world” and his “girlfriend world” collide there will be an explosion.
I had a case of my worlds colliding over the holidays. Let’s see what the results were. The attached pictures are from a leaf blower my husband received as a Christmas gift. It is a nice gift that will help us with yard work in the future. The description on the box says it comes with a charger for the included 40 volt, 2.0 ampere-hour rechargeable lithium-ion battery. On the back was the Lithium battery handling information. I didn’t pay much attention to it due to being in a cookie coma from the holidays.
Upon arrival home and while unloading the car, my husband noticed the information on the box and pointed it out to me. He then asks, “Should this be on here?” Needless to say, once we were fully unpacked I grabbed my regulations just to see.
Using the information on the box let’s review some points for shipping Lithium-ion batteries. Bear in mind this was purchased at a store where it was on the shelf. I have no way of knowing if it was shipped in this box.
- Step 1: Is this lithium-ion battery is “contained in equipment” or “packed with equipment”?
- Answer: The battery was not inserted into the blower but in a separate box beside it. This means it would have been “packed with equipment”.
- Step 2: What is the watt-hour rating?
- Answer: This was easy enough since the box said the battery had a 2 ampere-hour capacity and a voltage of 40 volts. Using the following formula:
Watt-hours = Ah (ampere-hours) x V (voltage)
Watt-hours = 2 Ah. X 40 volts
Watt=hours = 80 watt-hours
- Step 3: What would be the proper identification number, shipping name, hazard class, and packing group (ISHP) if this had been shipped?
- Answer: Since the manufacturer is within the US, I looked at the US ground regulations, 49 CFR. It is a Lithium-ion battery that was packed with equipment. Using the Hazardous Materials Table (HMT) that tells me the proper ISHP would be UN3481 // Lithium-ion batteries packed with equipment // Class 9 // no packing group.
- Step 4: What sort of packaging requirements are there?
- Answer: Again the HMT gave me that information in column 8. Luckily for UN3481 the packaging information is all found in Section 173.185. The only Special Provisions listed in the table are for air shipments. Much of this section didn’t apply to my query because I wasn’t shipping this. However, this section is also where all of the marking, labelling, exceptions/exemptions and hazard communication information is found.
- Step 5: Where does the leaf blower fit and why was that particular safety information used?
- Answer: This goes back to the information from Step 2. The watt-hour rating of 80 put me into Section 173.185(c) for exceptions. In that section is where the hazard communication information is found. In that was the proof I needed to say, “It is ok for this information to be on this box.” The box only has 1 lithium battery and the box is using the “handling marking” shown in paragraph (c)(3)(ii). The regulation says the following:
(3) Hazard communication. Except for a package containing button cell batteries installed in equipment (including circuit boards), or no more than four lithium cells or two lithium batteries installed in the equipment:
(i) For transportation by highway, rail and vessel, the outer package must be marked with the information in the following paragraphs (c)(3)(i)(A) to (D), or the handling marking in paragraph (c)(3)(ii) of this section:
(A) An indication that the package contains “Lithium metal” and/or “Lithium ion” cells or batteries, as appropriate, or alternatively, the word “batteries” may be used for packages containing cells;
(B) An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged;
(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary;
(D) A telephone number for additional information.
(ii) For transportation by air, the outer package must be marked with the following handling marking, which is durable, legible, and displayed on a background of contrasting color:
So there it is the results of my worlds colliding. There were no explosions, tidal waves, or earthquakes. There were no deaths from licking cheap envelopes, which is a reference to Susan’s fate. It was just an exercise of taking ICC Compliance Center’s “7 Steps to Compliance” idea and making them work for me. Of course, my head may explode when HM215-N is finalized and the information in this section of 49 CFR changes.
As always, ICC Compliance Center is here for all of your hazard communication and lithium battery needs. Call us today for lithium battery training, new class 9 labels or new handling marks, and new lithium battery shipping materials. We have it all.