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 188.8.131.52). 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…
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…
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…
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.
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!
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…
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. Due to the Holiday week, we have only 2 FAQ’s worth sharing.
Check back weekly, the helpdesk rarely hears the same question twice.
More Lithium Batteries
Q. We want to ship a 63 W-hr lithium ion battery. Are there any issues with packaging 2 or more together in the same container under IATA 2018 and 49CFR? If 2 or more are ok what is the limit?
A. Under IATA you have 2 options and it will be up to you as the shipper to make the decision as to how to handle your shipment. As you know the 65 w-h battery falls into the excepted type. Now, for IATA that puts you in either Section II or Section IB. By the way, be sure to grab the recently published Addendum!
For Section II batteries there is a change for this year. As per usual, there are several changes to the operator regulations. Also, these batteries cannot be packed in the same outer packaging as any other dangerous goods.
The rest of the section still applies in PI 965. You are not allowed to offer more than 1 package prepared under Section II in any single consignment or shipment.
If you are using an overpack, you can only have one package of these batteries in the overpack. The overpack cannot Continue Reading…
Sometimes we try to find an economical solution to comply with regulations. If it works, great, but sometimes – actually most times – it comes back to bite us in the behind.
Last week a customer of ICC’s came in panicking to get help. He has previously used us a few times for our repackaging service. Let’s call him Bob. Bob told me he and his team took an online training course which certified them to ship lithium batteries via air. Bob’s shipper packaged up a lithium battery shipment and had sent it out. Bob just found out that it was rejected by the carrier. I asked Bob which UN# they used and he said UN3481. Asked him which (packing instruction) section and he said “what?”. I said, “In Packing Instruction 967, which section do you fall under?” He said, “What’s a packing instruction?”. I grabbed my IATA regulation and told him, “You guys used this book to do the course, yeah?” and he inferred that the course didn’t require use of a book and no, they didn’t use any books. I asked Bob if they took training with ICC and he said, “no”. Bob said they took training with another company and paid $50 as it was the cheapest training they could find. I told him that was his first mistake.
The wording in recent, current and upcoming editions of the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) has some potential to confuse the regulated community, especially regarding shipping lithium batteries.
Exemptions Restricted or Not?
The paragraph providing an exemption from the lithium battery mark (pka “Handling Label”) is found in the last sentence of the second paragraph in Section II “Additional Requirements”, for the packing instructions (PI) for both UN3091 and UN3481 “contained in…” lithium battery entries:
This requirement does not apply to:
packages containing only button cell batteries installed in equipment (including circuit boards); XXX
consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.
The “XXX” is the key that led to this discussion.
2016 as the Baseline:
In the IATA DGR 57th (2016) Edition, both PI 967 and PI 970 (“contained in equipment”, ion and metal respectively), the “XXX” in each case read “or”.
In other words, whereas cells/batteries other than button cells were limited to 2 packages per consignment, the number of packages per consignment were not limited when there were only button cells (of course, the maximum net battery weight per package restrictions in Table II of each PI must also be met).
Looking Forward to 2017?
Things then look as though they’re changing when reading the Appendix H (Intended Changes for Continue Reading…
Once again lithium batteries are in the news. The FAA is proposing a worldwide laptop ban in checked bags on international flights. Tests conducted by the FAA have concluded that when large electronics like laptops overheat in checked luggage, they run the risk of combustion when packed with aerosol canisters like hairspray and dry shampoo. As a result, the potential for explosion becomes a danger to the entire aircraft. The risks are certainly a lot higher if your lithium battery device does in fact catch fire on an airplane, but what exactly is the reason lithium batteries catch fire and what should you do if your device does catch fire during your daily routine?
What is Thermal Runaway?
Previously I wrote a blog on how to prevent lithium batteries from catching fire. But why exactly do lithium batteries catch fire? Lithium-ion and lithium-metal cells are known to undergo a process called thermal runaway during failure conditions. Thermal runaway results in a rapid increase of battery cell temperature and pressure, accompanied by the release of flammable gas. These flammable gases will often be ignited by the battery’s high temperature, resulting in a fire similar to the video below.
Another major reason behind thermal runaway is other microscopic metal particles coming in touch with different parts of the battery, resulting in a short-circuit.
Anyone who ships by air these days can relate to the frustrations associated with shipping lithium batteries.
A gentleman (let’s call him Jack for reference purposes) was given our contact information by Air Canada to get his motorcycle declaration completed. I provided Jack with the shipper’s declaration and he was able to ship his motorcycle with Air Canada. Jack is moving to Faro, Portugal (yes, I am jealous too!) and he is shipping all his personal effects. The broker that is helping Jack with shipping his belongings told him lithium batteries (his power drills) are dangerous goods and Jack needed to remove them, which he did.
Unfortunately the broker didn’t provide Jack with any directions on how he can ship them. So, when Jack went to drop off his motorcycle to Air Canada he asked about shipping his power drills and Air Canada cargo folks told him it’s DG and he needs to get it prepared for transport, and to call Air Canada (yes, you need to call the 1-800 number) for more information. Of course Jack did and Air Canada told him they can accept the shipment as long it’s prepared for air transport. That’s where I come in.
What Are Jack’s Options?
Jack then called me back. He said to me, “You seem to know what you are talking about when Continue Reading…
An iconic show from the 1980’s was “The A-Team”. It was about a group of former military men who worked to help those in need by using their former skill set. A famous line from it was often said by John “Hannibal” Smith, played by George Peppard. At the end of many episodes he would say, “I love it when a plan comes together”. With the publication of Transport Canada’s Amendment TDGR SOR2017 – 137, we finally have a plan coming together for the transportation of Lithium Batteries.
Finally, all transport regulations – 49 CFR, TDG, IATA .and IMDG – are on the same page regarding the necessary marks and labels needed for transporting Lithium Batteries. All of the regulations even have the same transition times for when the new Class 9 Lithium Battery Hazard Class Label and new Lithium Battery Mark will be mandatory.