ICC's Regulatory Helpdesk
Regulatory Helpdesk: Sept 3

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.

Lithium Battery Label (Ion/Metal)

Q: On the old lithium battery handling label, can I use an Avery address label for the words ion and/or metal?
A: What you propose is not the best option for lithium battery label. However, if it is your only option, then you most definitely will need to cover the Avery label with strong, clear packaging tape.  Regular old scotch tape won’t do as it won’t stand up to the durability requirements.

Adding an SDS to Your Shipment

Q: Do I have to put the SDS on each one of my hazmat boxes?
A: Technically, an SDS is not required to be attached to any packages.  Your carrier may request this though. If the SDS is being used as the “written emergency response information” required under 49 CFR and the US variation in IATA, then it should be with the shipping papers/declaration and not on the packages.

How Many Lithium Batteries Can Go in a Box?

Q: I have 4 pieces of equipment that are being shipped. Each has its own lithium metal battery inside a plastic bag. So, this is UN 3091 packed with equipment. The lithium content on each battery is 0.28 grams and weighs well under 1 pound each. Can I put all 4 pieces of equipment and the batteries in the same box or do they need separate boxes for IATA?
A: Under IATA PI969 you meet the excepted battery criteria. This means no UN specification packaging. Given the weight of each battery, you are allowed to ship them all in 1 box on a passenger plane.

Will Any Old Lid Do?

Q: My company purchased some open head UN specification drums but no lids. I need to ship some material from the US to Canada in those drums. What do I do for the lid?  Can I just use one that fits? Does the lid have to have the UN specification mark on it?
A: First of all, you need to find and purchase the lid used when that particular drum was tested. It should be disclosed in the manufacturer’s packing instruction.  You cannot use one that just fits as that would invalidate the UN specification testing report. The lid will not have the UN specification marking on it.  As for going into Canada, as long as the small means of containment is UN rated there would be no limitations on using this type of packaging.

Lithium Battery Segregation (49 CFR)

Q: Customer called and asked if he was allowed to ship a regulated lithium battery in the same package as a class 8 corrosive that he will be shipping under the small quantities exception §173.4 in the 49 CFR per ground.
A: Per §173.24 (e) (4), as long as the 2 substances (small quantity class 8 substance and the lithium battery) aren’t capable of reacting dangerously with each other, they are allowed to be shipped in the same package. If that is true and they are safe, you would have to use the small quantity label for the corrosive if it meets those regulations along with the proper lithium battery labels as well on the outside of the box.

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