Lithium Battery
Passengers Traveling with Lithium Batteries

Inside passenger airplane

Thinking About Lithium Batteries as a Passenger

Recently in my travels, I found myself stuck in a long security line at our local airport. Being that it was during Spring Break, there was a wide variety of travelers from college students to retirees looking to re-connect with family. Although there were people of all ages and travel experience they all seemed to have one thing in common, they were confused how to travel with their laptop computers and other types of portable electronics containing lithium batteries. Let’s discuss some general guidance on how to travel with specific portable electronics that contain lithium batteries referencing some recently issued documents by IATA.

Portable Electronic Devices (PED) Containing Batteries

close up of man holding cellphone in front of laptop

Portable Electronic Devices including electronics such as cameras, mobile phones, laptops, and tablets containing batteries carried by passengers for personal use should be carried in carry-on baggage.

For devices that can be packed in checked baggage:

  • The device must be protected from damage and to prevent unintentional activation;
  • The device must be completely turned off (not in sleep or hibernation mode). 

Spare lithium batteries

Lithium Battery

Each spare battery must be individually protected to prevent short circuits by placing them in the original retail packaging or by otherwise insulating terminals by taping over exposed terminals or simply placing each battery in a separate plastic bag or protective pouch and carried in carry-on baggage only. Items that contain Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 2

How to determine if a product is regulated, SAPT on a SDS, Shipping a drone, and using a UN package

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.

Is my product regulated?

Q. I have 2 products I distribute to various stores to sell. The SDS files say my product is not regulated under DOT and TDG in Section 14. Since this is sold as a consumer product, doesn’t that mean it is regulated for IATA should I ship it via air? (the SDS were emailed to me)
A. Nothing in your SDS files leads me to believe either one would meet any of the 9 hazard classes in IATA. This is further confirmed by neither SDS classifying the products for DOT and TDG. Basically, what you have are containers of non-regulated liquids.  There is no need for UN Specification packaging or paperwork for IATA or any other transport regulation.

SAPT on my SDS

A. Since the addition of UN numbers for polymerizing substances, we’ve been told we must include the Self-Accelerated Polymerization Temperature (SAPT) on our SDS documents in Section 9. Is this a new requirement?
Q. There is no requirement in OSHA HazCom 2012 to include that particular data point in Section 9. All of the Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: March 19

Proper Shipping Name, Hydrostatic Pressure Tests, Other Information on the Lithium Battery Mark, and an Interesting Lithium Battery Story

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.

Proper Shipping Name for Lithium Batteries (IATA)

Q. Is it acceptable to print “Lithium Ion batteries packed in equipment” on a Class 9 Miscellaneous lithium battery label for UN3481 instead of Lithium Ion Batteries Contained in Equipment?
A. Yes. In the blue pages (Section 4) of IATA, you will notice there are 2 spots for UN number “3481”, one for lithium batteries containing equipment, and one for lithium batteries packed in equipment, so either of those printed on the label is acceptable.

Hydrostatic Pressure Test by Air (IATA)

Q. I plan on shipping an F-style container as an inner container in a combination package. Per IATA  §6.3.5.1, it says the internal pressure test is not required for combination packages. Does this mean the inner container doesn’t have to meet the 95 kPa pressure rating if shipping liquids by air?
A. Although IATA §6.3.5.1 does state the internal pressure test is not a required test for inner packagings of combination packages, it also references §5.0.2.9 for further instructions, which states that packaging for retention of liquid must be capable Continue Reading…
Regulatory Helpdesk: March 5

Batteries, Batteries, and more Lithium Batteries

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.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.
A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 Continue Reading…
Regulatory Helpdesk: February 12

Lithium Batteries, Placards, and SDS in the Workplace

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 Batteries (Air)

Q. For PI 967 in IATA is the weight limit the weight of the equipment and battery inside of it or just the battery.
A. For all battery packing instructions in IATA it is always the weight of the battery itself.

Lithium Batteries (IMDG)

Q. Do “excepted” batteries require segregation from limited quantity packages under IMDG?
A. Under IMDG §3.4.4.2 it tells you that segregation requirements in Chapters 7.2 – 7.7 plus any information on Stowage in column 16b of the table do not apply to goods in limited quantity packages. Lithium ion batteries do not yet need segregation under IMDG either. It is only IATA that has implemented segregation this year as part of the packing instructions for shippers. IATA has also added batteries to the segregation table for operators, but it isn’t mandatory until next year and only applies to those in Section 1A and 1B not Section II.

Placards (TDG)

Q. Customer asked if his Class 8 material (UN 1830) needed to have a UN number on the placard if shipping 1 liter per package and 7 per tote for a total of 17 Liters for the shipment in Canada. Continue Reading…
Airplane Icon
191 Lithium Battery Incidents Reported Since 1991

Lithium Batteries, Laptop battery

Airport Lithium Battery Incidents

In our dangerous goods world we all know the importance of labelling, packaging, and disposing of lithium batteries. As many of you know we offer training, consultation, packaging, and re-packaging for shipping lithium batteries, and for good reason. While lithium batteries are becoming more and more prevalent in our society, so are the risks involved, like the video below:

According to the FAA as of January 24, 2018, there were 191 air/airport incidents involving lithium batteries carried as cargo or baggage that have been recorded since March 20, 1991.

And just to clarify, these are just the recent cargo and baggage incidents that the FAA is aware of. Most of these incidents included smoke, fire, extreme heat or explosion involving lithium batteries or unknown battery types. Incidents have included devices such as E-cigarettes, laptops, cell phones, and tablets. The severity of these incidents ranged from minor injuries to emergency landings.

Visit FAA’s website for the complete list of incidents:

https://www.faa.gov/ (PDF)

Note: This list does not include three major aircraft accidents where lithium battery cargo shipments were implicated but not proven to be the source of the fire.

What can we do to prevent these incidents?

The following precautions should be taken when traveling with devices containing lithium batteries:

  • Never travel with a device with a damaged or defective battery.
  • Make sure battery is properly installed in your device. Batteries Continue Reading…
Regulatory Helpdesk: February 5

Labels, Placards, Segregation, Documentation, SDSs & Emergency Response

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.

Here are the top 6 questions from last week.

SDS and Workplace Labels

Q. If I have a product like a concentrated cleaner which is corrosive to the eyes and skin that I water down at my facility, do I need a new SDS and workplace labeling?
A. You have 2 options. You can use the SDS as provided to create your workplace labeling. This may cause concern with your workers. However, it would be better for you to develop your own and re-evaluate the product using the hazards presented in the watered-down version. It is possible, depending on how diluted it is, to move into the irritation or non-hazardous range.

Listing Canutec or Chemtrec on Lithium Battery Marks

Q. Regarding the new battery mark, am I allowed to add “in case of emergency, contact Chemtrec”?
A. The regulations are pretty clear (DOT §173.185(c)(3) and IATA 7.1.5.5). What should be listed there is a phone number for “additional information”. There should be no extra phrasing other than phone number itself. As for listing Chemtrec, Infotrac or even Canutec, those are 3rd party Emergency Response Providers and would not be appropriate to include in that section of Continue Reading…
Lithium Battery
Lithium Battery Placarding and Segregation

Lithium Batteries, Laptop battery

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 Continue Reading…

Airplane Icon
My Suitcase is Following Me! Can I Take it on the Airplane?

luggage at an airport

Smart Luggage: Regulations and Technology

In the world of dangerous goods regulations, frequent changes are the norm. These changes may happen for a variety of reasons. With technology constantly moving forward at a fast pace, the dangerous goods regulations often times have to update accordingly. Within the last 40 years or so, we have been introduced to a variety of new products that contain lithium-ion batteries. From laptops to smartphones, the introduction of these products into society has caused dangerous goods regulators to be in a constant foot race to keep up with the newest lithium battery powered electronics. The newest craze we see in the electronic world is the introduction of battery powered smart luggage.

What is smart luggage?

If you have ever watched The Jetsons, When George arrives at work in the introduction, his car folds down into a briefcase for him to carry inside. 

While smart luggage isn’t exactly what George Jetson used, they do have many amazing features. Built-in features in smart luggage include GPS locators, weight scales that prevent over-packing, USB ports to charge your devices, and remote lock systems. Smart luggage is a game-changer in the travel industry, as they can help you navigate the airport and let you know where it is if it did not follow you to your destination. They even have the ability to follow you around the airport like a robot, which I’m Continue Reading…

Repacking Dangerous Goods
Shipping Laptops to Australia

Lithium Batteries, Laptop battery

Shipping Laptops Means Shipping Lithium Batteries

If you were to ship a laptop 5 years ago, all you would need to do was pack it up and ship it. Like shipping socks. But now that same laptop is considered a dangerous good due to the lithium battery it contains.

The Situation

I had a customer drop off 2 laptops going to Australia. He wanted me to prepare the shipment for air transport as he isn’t certified to ship dangerous goods via air. He said he received about 6 pallets of marine vessel equipment returning from Canada to Australia and he said someone put these 2 laptops in one of those pallets thinking it can all go as general cargo. He knew that there are restrictions on shipping lithium batteries via air so he knew he had to call in the expert!

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The Solution

I removed the battery from the laptop to see the watt hour rating. It was 41-watt hour and the total net quantity of lithium was below 5 kg (well below). Which meant these laptops are classified as Section II for UN3481, Lithium ion batteries contained in equipment; therefore, does not require a shipper’s declaration. It’s always good news for the client when it falls in Section II as it saves the client money.

I placed both laptops inside a good strong box (each laptop was initially Continue Reading…