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Truck and Track
Spring 2019
www.truckandtrack.com68
DANGEROUS GOODS
We all use lithium batteries of varying types. In fact they are
likely to be with us, or on our person, most of the time. They
are in watches, mobile phones, laptops, power chargers, car
keys and a myriad of devices and portable equipment. It is
estimated that consumer use of lithium-ion batteries is likely
to increase by 50% in the next five years. Typically, lithium-ion
batteries, and variants thereof, tend to be re-chargeable and
lithium metal batteries are usually for single use although, as
technology evolves, this is not always the case.
Of course, the flexibility that modern batteries allow has
transformed industry too, and the increase in shipments will only
continue, with the consequence of more and more businesses
falling under the scope of the regulations.
Lithium batteries have to be tested to UN standards. They are
classified as dangerous goods (DG) and UN numbers have been
allocated for each type:
■■
3090: LithiumMetal Batteries (including lithiumalloy batteries)
■■
3091: Lithium Metal Batteries contained in / packed with
equipment (including lithium alloy batteries)
■■
3480: Lithium Ion Batteries (including lithium polymer
batteries)
■■
3481: Lithium Ion Batteries contained in / packed with
equipment (including lithium polymer batteries)
■■
3536: Lithium Batteries installed in Cargo Transport Unit
(lithium ion or lithiummetal)
I started by asking Geoff, “What makes lithium batteries hazardous
and what are the risks in transit?”
GL: Lithiumbatteries containmore energy thanmany other battery
types, allowing our portable electronic devices to run for hours
or even days. Batteries manufactured and tested in accordance
with very strict provisions laid down by the United Nations are
perfectly safe but, because of their high energy, if batteries are
abused or are fake or counterfeit, they can experience a condition
called “thermal runaway”, where the temperature increases
uncontrollably to a point where the cells in the battery catch fire,
typicallywith dramatic effects. Consequently, themodal dangerous
goods requirements try to ensure this will not occur in transport,
by prescribing how batteries must be tested and prepared for
transport, and how packaging must also be tested, marked and
labelled. With some exceptions for smaller batteries, shippers must
also provide information on their consignment to the operator/
carrier and also make a declaration that all applicable provisions
have been complied with.
RS: There are UN tests that lithium batteries have to pass before they
can be shipped. What does this involve?
GL: The UnitedNationsManual of Tests and Criteria contain a series
of tests, known as the 38.3 tests. There are eight tests: altitude
simulation, thermal, vibration, shock, external short circuit, crush,
overcharge and forced discharge. All lithium cells and batteries
have to be tested to some degree, although there are provisions in
all of the modes of transport for prototype and low production runs
(annual production of not more than 100) to be shipped without
meeting the test requirements if they are being transported for the
purpose of testing.
RS: There are strict regulations that control not just the batteries
themselves but also the classification, packing, marking and shipping.
Why are there so many Packing Instructions and Special Provisions?
GL: The air mode has six Packing Instructions for lithium batteries,
three each for lithium ion (rechargeable) and lithium metal
(typically non-rechargeable). These Packing Instructions contain
provisions for batteries shipped on their own, packed with
equipment and contained in equipment. These requirements are
contained in only one Packing Instruction in the road and seamode
requirements. The air mode requirements for lithium batteries are
the most restrictive of all the modes of transport due mainly to a)
limited options - if a problem occurs in flight, the aircraft may be
many hours from a suitable diversionary airport; and b) unlike the
other modes of transport, carriage may be on either a cargo aircraft
or a passenger aircraft, in which case accompanying the cargo may
be upwards of 500 passengers and crew. With regard to special
provisions, 188 in both the road (ADR) and sea (IMDG) modes is
particularly significant as it provides an alleviation of many of the
requirements for the transport of smaller cells and batteries. These
provisions are also contained in the air mode requirements but,
instead of being in a Special Provision, they are contained in the
Packing Instructions referred to previously, which is also a factor in
there being more Packing Instructions in the air mode compared to
road and sea.
RS: To minimise the impact of a lithium battery incident, especially on
board an aircraft, the UN has set up a forum to consider a certification
scheme for fire resistant and heat retaining packaging (G27 group).
No doubt this will have cost implications for those shipping lithium
batteries by air. Do you think that it will be a requirement for other
transport modes?
Shipping LithiumBatteries –
The Myths Unravelled
Richard Shreeve, Compliance Manager at
Labeline International, asks Geoff Leach, former
Chairman of the International Civil Aviation
Organization’s Dangerous Goods Panel, and who
now Chairs IATA’s Lithium BatteryWorkshops,
to give an overview of the requirements for
shipping lithium batteries by all modes of
transport.
Richard Shreeve
Geoff Leach