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.
One of my favorite cartoons growing up was “Scooby Doo”. Nothing made me laugh more than when Scooby would say, “Ruh roh, Raggy” when he was trying to say, “Uh oh, Shaggy”. This was usually in situations where things had gone terribly wrong. I had one of those moments recently and it was in regards to lithium batteries.
In one of my recent training classes, we were digging into the IATA Shipper’s Declaration and how to complete it. Anyone that handles these knows there are lots of things to include. As the discussion moved to the “Nature and Quantity of Goods” section, we were cruising. Everyone understood the process and how great IATA is about explaining what goes where. The examples in Chapter 8 are awesome!
The “Ruh roh” moment came as we were discussing the inclusion of the Packing Instruction number. Most of us are familiar with the first part of that step. It tells us that for all of our shipments, we add the number of the Packing Instruction we followed for said shipment. In Section 184.108.40.206.3 of IATA, it says the following:
Step 8. Number of Packing Instruction or Limited Quantity Packing Instruction (with its “Y” prefix) (Columns G, I or K). For lithium batteries prepared in accordance with Section IB of Packing Instruction 965 or Packing Instruction 968 the letters “IB” must be added Continue Reading…
On March 25, 2017, the United States government implemented a ban on passengers bringing carry-on electronic devices such as laptops on board certain airlines. This ban will affect electronics that exceed the size of a cellphone—typical products that will be banned include laptop computers, tablets such as the iPad and Android versions, gaming devices larger than a cellphone, DVD players, and portable printers and scanners. These devices may still be carried by travelers, but must be stowed in checked luggage during the flight. Medical devices will be exempted from the restrictions.
The ban affects flights leaving from ten airports in eight Middle Eastern countries.
Airports Involved in the Ban:
Abu Dhabi International Airport, Abu Dhabi, United Arab Emirates
Ataturk International Airport, Istanbul, Turkey
Cairo International Airport, Cairo, Egypt
Dubai International Airport, Dubai, United Arab Emirates
Hamad International Airport, Doha, Qatar
King Abdulaziz International Airport, Jeddah, Saudi Arabia
King Khalid International Airport, Riyadh, Saudi Arabia
Kuwait International Airport, Kuwait City, Kuwait
Mohammed V Airport, Casablanca, Morocco
Queen Alia International Airport, Amman, Jordan
The ban affects flights of the following airlines leaving from any airports listed above:
Royal Air Maroc
Royal Jordanian Airlines
The ban is intended to only apply to direct flights from these locations to the U.S., which would total just about 50 flights a day. Continue Reading…
As the cold weather comes to an end (hopefully sooner rather than later) and we turn the corner and head into spring, we will realize that we have our work cut out for us in our backyards. Once the snow melts and the reality sets in that we have a lawn and garden that will need attention, into our sheds and garages we will go to dust off our battery or gas powered lawn equipment to get the job done. Using the lawn equipment may seem pretty straightforward, but we must realize that this equipment is powered by gasoline and lithium-ion batteries, which if not stored and used correctly, or under the wrong circumstances, can be quite dangerous. Below are some safety tips for gasoline and battery powered lawn equipment.
Safety Tips for Gasoline Powered Lawn Equipment:
Store gasoline in an approved container or tank. Keep gasoline containers tightly closed and handle them gently to avoid spills.
Gasoline is a flammable liquid and should be stored at room temperature, away from potential heat sources such as the sun, a hot water heater, space heater, or a furnace, and a least 50 feet away from ignition sources, such as pilot lights. Gasoline vapors are heavier than air and can travel along the floor to ignition sources.
Both 49 CFR and TDG are expecting to harmonize lithium battery labels into the regulations; however, both regulations are pending. HM-215N (49 CFR) was recalled, and will not be reissued for at least 60 days.
Transport Canada has not provided an ETA on the harmonization.