ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 25

Carrier Variations, WHMIS vs. OSHA, Placarding, Lithium 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. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Carrier Variations

Q. Can you help me understand what I did wrong or how to respond to them?

DHL is the carrier for my product. It is UN3077 and it is packaged 25 kg per fiberboard box. They sent me the following comments regarding my shipment.

They told me the country of USA must be a part of my address on the shipper’s declaration. They also said I had to use PI 956 even though it is marked and labeled as a limited quantity shipment. Finally, they told me I had to include the place and title on the shipper’s declaration.

A. First of all, carriers can ask for things beyond what is in the regulations. Sadly, you must comply with their requests if you want your shipment to proceed. Having said that there are a few things about your points that I can provide some regulatory framework for should you choose to push the issue with them. As to the country of USA being required, the IATA regulations never Continue Reading…
Lithium
Detained Battery Shipment – Fixed!

AA sized lithium battery cells

What Happens When Watt-Hour is not Marked on Each Battery?

Well a few things – beginning with the shipment being stopped until the error is corrected by trained personnel like us.

It is mandatory to have the watt-hour marked on a lithium ion battery (unless it’s manufactured before January 1, 2009), and batteries that don’t display this mark are considered non-compliant for transport. To bring it in to compliance each battery must be marked with the watt-hour.

Doesn’t seem too bad, right? Wrong.

Imagine individually marking 11,600 little batteries.

These batteries were the size of AA batteries. Each individual battery was packaged in its own little box. Like a lipstick box. Then these little boxes (20 in total) were placed in a larger box. Then the larger boxes were placed inside a bigger cardboard box. Never had I done a job this tedious. Add to this trying not to break the small flap on the little boxes when opening these boxes.

The first day was a disaster as we weren’t prepared with the right tools. Finger nails were hurting from opening the little boxes. That night ideas were rolling in everyone’s head on how to efficiently do this job as it took 7 hours, and 2 people to finish 800 batteries. At this rate it would take 2 weeks to do this job.

The next day a tool was brought to speed up Continue Reading…

ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 11

Segregating Flammable Gas and Explosives, WHMIS/OSHA Labeling, Lithium Batteries, Orientation Marks, and Net vs Gross

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.

WHMIS/OSHA labeling

Q. Is a WHMIS 2015 compliant label going to be compliant within OSHA HazCom2012?
A. Maybe. While both the Canadian and US version of the GHS are very similar there are some differences in phrases used in regards to precautionary phrases. Also, WHMIS 2015 has the additional possibility of classifying something as a biohazard that is not found in the US standard. The best course of action would be for ICC to review your label for compliance within the 2 regulations.

Segregating Flammable Gas and Explosives (TDG)

Q. Is it okay to ship a class 2.1 dangerous good with a class 1.4 explosive in the same box shipping ground in Canada?
A. While the TDG and TP14850 do not have a segregation table, TP14850 12.89 states that Dangerous goods must not be offered for transport together with other dangerous goods or non-dangerous goods in the same container or overpack if the combining of those goods could:

  1. result in an evolution of heat or gas, or produce a corrosive effect or the formation of unstable substances that could endanger the integrity of the package or overpack; or
  2. cause a Continue Reading…
Lithium
How to Ship Damaged or Defective Lithium Batteries

Swollen lithium polymer batteries. Dangerous and harmful electronic waste

Regular Damaged or Defective or Dangerous Damaged or Defective?

There is a fair amount of interest in the topic of preparing Damaged or Defective (DoD) lithium batteries for transport and how to make a determination of the degree of hazard they present.

The current (20th) 2017 Edition of the Recommendations on the Transport of Dangerous Goods (UN Model) Regulations have addressed the former (packaging for transport) aspect, but the documents currently posted have not yet established firm protocols for the latter.

The situations involving recalls of defective, unsafe batteries and incidents during transportation has sustained the efforts to find better ways of dealing with them. The topic has been under discussion at the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods (TDG) in most sessions over the last several years.

For this discussion we’ll refer to cells/batteries that do not meet the UN Manual of Test criteria due to damage or defect, without specific safety hazards, as “regular” DoD; and those that “are liable to disassemble rapidly, react dangerously, produce a flame or a dangerous evolution of heat, or produce a dangerous emission of toxic, corrosive or flammable gases or vapours” as “dangerous” DoD.

This distinction is proposed for clarification in the next version (21st Edition) of the UN Model. See, for example, working document ST/SG/AC.10C.3/2018/51:
http://www.unece.org/fileadmin/DAM/trans/doc/2018/dgac10c3/ST-SG-AC.10-C.3-2018-51e.pdf

Batteries or Reactive Substances?

As a technicality, we should pause to consider the basic Continue Reading…

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…