Get familiar with the dangerous goods regulation and advise others
Concerned with the safety of shipping lithium-based batteries by air, the Air Line Pilots Association (ALPA) promoted tighter restrictions and requested that lithium batteries be declared regulated dangerous goods that are shipped by cargo aircraft only. PRBA, on the other hand, supports the current International Civil Aviation Organization (ICAO) requirement that has been in effect since 2009 but was never applied in the US. ICAO is the United Nations agency that sets international aviation standards. It’s up to each country to decide whether to follow the standards, but most do.
The shipment of nearly all lithium-based batteries must pass section 38.3 of the UN Manual of Tests and Criteria. The International Air Transport Association (IATA) assists by publishing the IATA Dangerous Goods Regulations (DGR) that helps classify, mark, pack, label and document dangerous shipments. DGR is recognized by all major airlines and the guidelines are based on international and national air regulations as well as on airline-specific requirements.
The quantity of batteries permitted in a shipment is based on watt-hours (Wh). Wh reveals the lithium content (ELC) by multiplying voltage by ampere-hours (Ah), in which 1Ah has 0.3 grams of lithium. For example, 14.40V x 5Ah battery = 72Wh (5Ah x 0.3g = 1.5g x 4 cells in series = 6g). New regulations are being discussed that might mandate to ship all Li-ion at 30 percent SoC. Li-ion is more stable at low SoC than when fully charged.
Under DGR, the packaging instructions (PI) are organized into PI 965 to PI 970. PI 965 covers Li-ion cells and battery packs only while PI 966 includes Li-ion installed in equipment and PI 967 combines Li-ion with equipment. Because of higher lithium content, lithium-metal batteries are handled separately under PI 968 to 970. (Most lithium-metal are non-rechargeable.) The paper also describes what a traveler can take on an aircraft.
|Most lithium-metal batteries are primary and have tighter shipping requirements than secondary Li-ion.|
To accommodate the traveler and the need to ship batteries, transporting lithium-based battery products is divided into two categories:
To make the rulings more palatable, the following tables list the less stringent requirement first, followed by the shipments of larger quantities of lithium-based batteries; the established numbering system suggests the reverse. Sections IA, IB and II are in Roman numerals and mean Section 1A, 1B and 2 in Latin numbers. When shipping regulated dangerous goods there must be an inherent level of trust as rules can be evaded. Shippers must sign and self-certify that a shipment complies with the applicable regulations.
Shipping rules are changing and effective April 2016, Li-ion cells and packs must be offered for transport at a state-of-charge (SoC) not exceeding 30% of their rated capacity. The SoC limit does not apply to Li-ion that are packed with or installed in products. Li-ion with low charge pose less danger than when fully charged.
At 30% SoC, the cell voltage of most Li-ion is ~3.70V. Discharge the battery to 3.65V/cell. The 50mV overshoot compensates for the rubber band effect. (See BU-702: How to Store Batteries.)
Packaging Instruction 965 —includes loose Li-ion cells and battery packs (UN 3480)
Table 1 divides the transport of Li-ion products into four groups: Carry-on defines the quantity of Li-ion cells and battery packs a passenger can take on an aircraft; Section II specifies shipment of small Li-ion products in low numbers; Section 1B advises on the shipment of small Li-ion products in larger numbers, and Section 1A governs larger Li-ion products. Only Carry-on and Section II are exempt from Class 9 hazardous material designation. IATA mandates that cells and battery packs cannot be combined in the same shipping box. Use separate boxes.
Table 1: Packaging Instruction 965 covering Sections II, IB and IA: Shipment of loose Li-ion cells and battery packs.
1 Effective April 2016
Passenger Aircraft Ban: Under Sections II, IA and IB, Li-ion is forbidden on passenger aircraft. All packages must bear the Cargo Aircraft Only label in addition to other required marks and labels. This limitation does not affect lithium ion batteries packed with or contained in equipment.
State-of-charge Limits: Li-ion must be shipped at a state-of-charge of no more than 30% of the rated capacity. This does not apply to batteries packed with or contained in equipment.
Other Restrictions: Shipper can only offer one Section II package (batteries only) per consignment.
Lithium battery shipments must be separated from other cargo. 2 Typical smartphone or tablet battery
3 Typical laptop battery
|Travel:||Passengers must carry batteries on board the aircraft. Check-in is not permitted. Non-removable batteries enjoy exemption (out of sight, out of mind).|
|Safeguard:||Batteries must be protected against short circuit. (Place in individual plastic bags|
|Approval:||A battery pack must be approved even if the cells in the pack have already been approved. Modified battery packs must also be reapproved.|
|Labels:||Each package must include the CAUTION label and the Lithium Battery Handling label with the words "Lithium ion batteries in compliance with Section II of PI 965” (or other applicable PI numbers). Add a contact phone number.|
|Overpack:||Under the new rule effective April 2016, the overpack cannot contain more than one (1) package in accordance with Section II of PI 965. The overpack can, however, contain other non-dangerous goods or compatible dangerous good items. Add the overpack label on the shipping box together with the other required labels with respect to multiple packages of regulated batteries.|
|Damage:||Batteries identified as defective and in danger of failing in transport are forbidden.|
|Old batteries:||Lithium-based batteries for disposal are forbidden from air transport unless approved by the appropriate authorities.|
|Packing:||Each shipping package must withstand a 1.2 meter (4 feet) drop in any orientation without damaging the batteries, causing them to shift or releasing the contents.|
Label: 120mm x 115mm
101mm x 74mm (4.0” x 2.94”)
Other dimensions may apply
Figure 2: Labeling for Packaging Instruction 965 covering Sections II, IB and IA. Section II is classified “Dangerous Goods” and is Class 9 exempt. Shipments must include Lithium Battery Handling Label and CAUTION label. Sections IB and IA are Class 9.
|Training:||Personnel handling lithium-based batteries for transport must be trained. Please see http://www.iata.org/training/courses/Pages/shipping-lithium-batteries-tcgp52.aspx|
|Approval:||All Li-ion batteries shipped under Class 9 hazardous material designation must meet the UN Manual of Tests and Criteria, Part III, subsection 38.3.|
Class 9 packages must include
100mm x 100mm (3.94″ x 3.94″)
Figure 3: Class 9 hazard material label. Shipment falls under Class 9 hazardous material designation. Class 9 label must be attached in addition to The Lithium Battery Handling and CAUTION labels.
PI 966 governs Li-ion cells and battery packs with equipment under UN 3481, and PI 967 oversees Li-ion cells and battery packs in equipment under UN3481 (Table 7-9). These rules are similar to PI 965 with the exception that Li-ion cells and battery packs can be shipped with, or in the equipment. Equipment means an apparatus requiring Li-ion products to operate.
Table 4: Packaging Instruction 966 and 967. Shipment of Li-ion batteries with, and in equipment.
|Limitation:||The maximum number of batteries in each package must be limited to those required to operate the equipment. Extras must be shipped separately or in an overpack. (Observe new rules effective 1 April 2016.)|
|Activation:||Equipment must be turned OFF. Accidental activation in transport must be prevented.|
|Exceptions:||Devices such as watches and temperature loggers that do not pose a danger in transport may be left in the ON position.|
Permits lithium-metal cells and battery packs (UN3090)
Lithium-metal batteries have tighter shipping requirements than lithium ion batteries. Most Li-metal is non-rechargeable, and it is used in watches, medical instruments, pacemakers, sensors, memory retention, etc. There are also consumer-grade lithium-metal in AAA, AA, 9V and other formats. Table 5 lists the restrictions in the shipment of these batteries.
Table 5: Packaging Instruction 968. Shipment of lithium-metal cells and battery packs.
Note: Effective 1 January 2015, lithium-metal batteries are restricted to cargo aircraft only. This applies to shipping lithium-metal batteries by themselves. Batteries packed with or contained in equipment can continue to be shipped on passenger aircraft.
Additional Requirements for lithium-metal batteries
|Packaging:||Cells and battery packs must be packed in a rigid outer packaging.|
|Padding:||Batteries must be surrounded by non-conductive, non-combustible cushioning material.|
|Label:||When package cannot meet above requirements, mark “Cargo Aircraft Only.”|
|Limitation:||Lithium-metal in any equipment must not exceed 12g/cell and 500g/battery.|
|Exceptions:||Button cell installed in equipment and circuit boards do not add to the battery count.|
300mm x 300mm (11.8” x 11.8”)
Other dimensions may apply.
Because of size, label cannot be printed on a regular printer.
Table 6: Package labeling for cargo aircraft only. The “Cargo Aircraft Only” label only applies to select large shipments of lithium-metal batteries. Colored label identifies package.
PI 969 includes lithium-metal with the equipment under UN 3091, while PI 970 rules include lithium-metal in the equipment, also under UN 3091 (Table 7).
Table 7: Packaging Instruction 969 and 970. Shipment of lithium-metal with and in equipment.
Current firefighting systems cannot suppress or extinguish a fire involving a significant quantity of lithium-based batteries on an aircraft with Halon 1301, the main chemical used. Aircraft manufacturers suggest that passenger aircraft should not carry lithium-based batteries in high numbers, a recommendation that would need to be approved by ICAO, DGR and other organizations. If agreed, the new ruling would come into effect in the 2017–2018 edition of IACO’s technical instructions of dangerous goods transport.
Dangerous goods shipping regulations can be circumvented by deliberately mislabeling batteries. There are reported cases where Li-ion was marked as benign NiCd and the stricter lithium-metal as Li-ion. Battery chemistries are difficult to identify, and such an offense may go undetected. Tightening rules only makes sense if the system can be made bullet-poof; imposing rules that are too stringent invites lawbreakers.
While every effort was made to ensure that the information contained in this publication is accurate, Cadex does not warrant or guarantee accuracy and completeness; nor does Cadex take responsibility for any errors, omissions or damages that may arise from this information.
These materials are provided as guidance only to assist properly trained shippers. All shippers are responsible to ensure they are properly trained to ship dangerous goods
Last updated 2017-01-10
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