This year’s Forum was held in Scottsdale, Arizona at the Hilton Scottsdale Hotel.
Sunday started with a course – Safe and Compliant Transportation of Batteries presented by Tom Ferguson (COSTHA) and Brendan Sullivan (IATA).
Japan does not allow the first year of an IMDG Code amendment to be optional, it is mandatory. For the 35th Amendment, the following do not apply during 2011:
- Limited quantity mark
- UN3171 Battery powered equipment
- UN3476 Fuel cell cartridges (packed with or in equipment)
For lithium, there are cells: cylindrical, prismatic and polymer; for batteries: laptop, camcorder, hybrid vehicles (to name a few). When looking at lithium, we need to look at cells vs. batteries. For lithium ion, we use ELC – equivalent lithium content or watt hour (Wh) rating. These can include lithium cobalt, lithium ion phosphate, etc. For lithium metal, the content of the lithium is used. Lithium cells/batteries are subject to the UN Manual of Test and Criteria, section 38.3. This section outlines the tests required, such as:
- Short circuit, and
If the cells/batteries do not pass the tests, then they would require competent authority approval.
For shipping lithium batteries by air, each packing instruction has 3 sections – general, section 1 fully regulated and section 2 excepted. For shipments under section 2, the requirements are similar to SP188 of the UN Recommendations. These are excepted shipments not non-restricted; in other words, the batteries are still dangerous goods. The lithium battery label of 120 x 110 mm can be reduced in size to 74 x 105 mm for smaller packages.
Section 1 is for fully regulated batteries. In the IATA Dangerous Goods Panel, for 2013, there will be a move away from gross weight. For 2011, there are 3 new special provisions – A181, A182 and A183.
Shipping lithium batteries under the IMDG Code results in the use of packing instruction P903. Nickel metal hydride (NmH) batteries are regulated under the IMDG Code. In the 35th Amendment, SP963 and SP117 apply. In column 8a of the Code, it reads “See SP963”. For quantities > 100 kg, a shipping document MUST state “Stow away from Heat”, and column 16 applies for segregation – stow away from heat. No marks, labels or placards are required.
The battery roundtable discussed recycling, focus on the auto industry, manufacturers will start collecting alkaline batteries later this year, need for the Wh marking and which regulations to use. Geoff Leach (UK CAA) stated that when he was last in Beijing, he was handed a map on where to buy knock-off products. This indicates that there needs to be training to overcome the cultural issue, so that only OEM tested materials are shipped. There is also a need to educate the passenger who TSA is looking at doing in the waiting line and/or during the aircraft safety briefing.
Geoff continued with harmonization in which he stated that confusion results where regulations differ resulting in frustration. The air acceptance requirements need to change to have some sort of undeclared dangerous goods protocol and develop standardized risk analysis. Some problems with shipping by air are batteries:
- Used batteries – not recalls but spent, holds no charge, etc.
- Relabeling – OEM ships regulated, properly marked/labelled batteries to Company A who rebrands the battery but it does not have the required label markings.
- Rebuilt/refurbished – some types of batteries can be rebuilt, but it still has the original label; the rebuilt battery should be retested but this does not happen
For shipping dangerous goods by air, the bottom line is safe travel.
(To be continued: Tuesday April 26, 2011)