Regulatory Updates: Lithium Battery Shipping Rules Mandatory

LITHIUM BATTERY SHIPPING RULES MANDATORY

On August 6, 2014, PHMSA updated the lithium battery shipping provisions of the Hazardous Material Regulations (HMR; 49 CFR 171-180). The lithium battery shipping rules are a step closer to harmonizing the US regulations with evolving international standards.

A Historical Timeline of Dates

Voluntary compliance with the new rules began immediately (Aug. 6, 2014), and the initial compliance deadline was 180 days after promulgation (Feb. 6, 2015). PHMSA later extended the deadline for shippers to August 7, 2015. Equivalent provisions for air and vessel shippers were part of the 56th Edition of IATA's Dangerous Goods Regulations (DGR) and the 2014 Edition of the IMDG Code (Amendment 37). The IATA DGR rules have been in force since January 1 of this year, and mandatory compliance with the 2014 IMDG Code starts on January 1, 2016.

What Changed for Lithium Battery Shippers?

1.    PHMSA's new lithium battery shipping regulations include three major components for lithium battery shippers:
DOT added definitions of the terms "lithium ion cell or battery," "Lithium metal cell or battery," "short circuit," and "watt-hour" to the HMR at 49 CFR 171.8.
2.    DOT officially incorporated all six Proper Shipping Names and four identification numbers for lithium batteries into the Hazmat Table at 49 CFR 172.101, instead of operating under a conditional authorization in place since 2009.
3.    DOT reduced the multiplicity of special provisions that governed the transportation of "small" lithium batteries, placing those detailed provisions within the packing instructions for lithium batteries at 49 CFR 173.185.

Lithium Battery Communication & Marking Rules

DOT no longer recognizes these two practices as of the August 6, 2015:

·         Packing Group Assignments: Previously batteries were assigned PGII.  Now, DOT and its international partners have eliminated packing group assignments for lithium batteries.
·         Exclusions from alternate marking for large numbers of small batteries: Previously, under Special Provision 188.f, DOT allowed shippers to avoid any labeling at all for packages that contained up to 12 small batteries or 24 small cells. Now, the only packages excluded from on-package hazard communications are lithium batteries contained in equipment and when there are no more than 2 batteries or 4 cells per package. [49 CFR 173.185(c)(3)]

This more complete harmonization between US DOT and international standards was made possible after international authorities agreed to prohibit most shipments of primary lithium metal cells and batteries from transport aboard passenger aircraft. [IATA DGR PI 968]


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