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Classification of Lithium Batteries for Transportation in Commerce

Classification of Lithium Batteries for Transportation in Commerce

Classification of Lithium Batteries for Transportation in Commerce

Persons involved in the transportation in commerce of lithium batteries are subject to the regulations of at least one – or perhaps all – of the following regulatory agencies:

  • The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT) for any transportation from, through, or to the United States.
  • The International Air Transport Association (IATA) for any transportation by air – international or domestic – if the carrier airline is a member of IATA.
  • The International Maritime Organization (IMO) for international transportation by vessel.
Though the dangerous goods regulations of IATA have not be adopted by PHMSA/USDOT, compliance with its regulations is acceptable since the IATA DGR are based on the Technical Instructions of the International Civil Aviation Administration (ICAO) - and are more strict in some cases - which has been adopted by PHMSA/USDOT.

Each of these regulatory agencies have very similar regulations applicable to the transportation of lithium batteries.  They each, thankfully, also have very similar – but not the same – requirements for the classification of lithium batteries in order to determine which regulations apply.  The classification of a lithium battery for transportation requires knowledge of four things:

  1. Is it a battery or a cell?
  2. The type of lithium battery.
  3. Its configuration.
  4. Its lithium content.

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The purpose of this article is to identify and explain the process of classifying lithium batteries for transportation by both domestic and international regulations.

Before we start:

Though terms such as “cell” and “lithium ion battery” and “Watt-hour ratings” are used in the same manner by all three agencies, they don’t each clearly identify the source or definition of these terms int their regulations.  For example:

  • The International Maritime Dangerous Goods Code does not define any of the terms related to lithium batteries.
  • The Hazardous Material Regulations of the PHMSA/USDOT define a lithium ion cell or battery and lithium metal cell or battery at 49 CFR 171.8.  A few more terms are defined in the packing instructions at 49 CFR 173.185.
  • The IATA Dangerous Goods Regulations define each term used in Appendix A and in its Lithium Battery Guidance Document.

The source of all of the terms related to lithium battery transportation, in the regulations and this article, have their origin in the United Nations Manual of Tests and Criteria, 5th revised edition.

Battery v. Cell:Lithium ion battery for cell phone

A battery is two or more cells electrically connected and fitted with devices for use.  A single cell lithium battery is considered a cell.  Units commonly referred to as battery packs, modules, or battery assemblies are batteries for the purposes of these regulations if their primary function is to provide a source of power to a piece of equipment.

A cell is a single encased electrochemical unit (one positive and one negative electrode).Lithium ion button cell battery  A cell for the purposes of the transportation regulations will be managed as a cell regardless if it is identified as a battery or a single  cell battery outside of the transportation regulations (e.g. its retail label).

button cell or battery is a round small cell or battery whose overall height is less than the diameter.

The distinction between a cell and battery is critical when determining the applicable packing instructions (see Lithium Content below).  However, throughout the regulations – such as in the selection of the proper shipping name (see Battery Configuration below) – the term battery is also meant to apply to a cell.

Type of Lithium Battery:

There are two types of lithium batteries.

Lithium metal batteries are generally primary (non-rechargeable) that have lithium metal or lithium compounds as an anode.  They are generally used to power devices such as watches, calculators, cameras, and temperature data loggers.  Lithium alloy batteries are a type of lithium metal battery.

Lithium ion batteries, or Li-ion batteries, are a secondary (rechargeable) battery commonly used in consumer electronics such as mobile phones and laptop computers.  Lithium ion batteries do not contain metallic lithium.  Lithium polymer batteries are a type of lithium ion battery.

Battery Configuration:

There are three configurations for lithium batteries identified in the transportation regulations.

Batteries packed by themselves without the equipment they are meant to power.  This may be one battery or several in a single package.  The shipping descriptions used by all three agencies are:

  • UN3090, Lithium metal batteries including lithium alloy batteries, 9
  • UN3480, Lithium ion batteries including lithium ion polymer batteries, 9
A lithium battery packed by itself is subject to the most stringent regulation.

Batteries packed with, but not contained in, the equipment they are meant to power.  The shipping descriptions used by IATA and PHMSA/USDOT:Lithium ion battery and flip phone

  • UN3091, Lithium metal batteries packed with equipment including lithium alloy batteries, 9
  • UN3481, Lithium ion batteries packed with equipment including lithium ion polymer batteries, 9

Batteries packed contained in the equipment they are meant to power.  The shipping descriptions used by IATA and PHMSA/USDOT:

  • UN3091, Lithium metal batteries contained in equipment including lithium alloy batteries, 9
  • UN3481, Lithium ion batteries packed with equipment including lithium ion polymer batteries, 9

While both IATA and PHMSA/USDOT have distinct shipping descriptions for lithium batteries packed with equipment and those contained in equipment (though both share the same identification number: UN3091 & UN3481, respectively and are largely packed and shipped in the same manner), the IMO joins these in one shipping description as indicated below.

  • UN3091, LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT or LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT (including lithium alloy batteries), 9
  • UN3481, LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT or LITHIUM ION BATTERIES PACKED WITH EQUIPMENT  (including lithium ion polymer batteries), 9

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Don’t be confused by the absence of the term cell in the available proper shipping names.  The regulatory agencies expect a shipper of a lithium cell to classify it according to one of the above configurations.

Size of Battery or its Lithium Content:

The amount of lithium in a battery is measured differently for lithium ion and lithium metal batteries.  For both, it is critical in determining how, or if, it will be subject to the regulations.  The threshold amount is the same for all three regulatory agencies.

The following batteries are subject to more strict levels of regulation due to their lithium content.

Lithium metal battery:

  • A cell containing >1 gram of lithium
  • A battery containing >2 grams of lithium

Lithium ion battery:

  • A cell with a watt-hour rating of >20 Wh
  • A battery with a watt-hour rating of >100 Wh

Lithium ion batteries above the threshold of 20 Wh or 100 Wh must be marked with their watt-hour rating if manufactured after December 31, 2011.

The batteries that follow are at or below the threshold amount and are subject to a lower level of regulation.

Lithium metal battery:

  • A cell containing ≤1 gram of lithium
  • A battery containing ≤2 grams of lithium

Lithium ion battery:

  • A cell with a watt-hour rating of ≤20 Wh
  • A battery with a watt-hour rating of ≤100 Wh

Lithium ion batteries at or below the threshold of 20 Wh or 100 Wh must be marked with their watt-hour rating if manufactured after January 1, 2009.58 Wh lithium ion battery

Most lithium ion batteries marketed to consumers are below 100 watt-hours.  If unsure of the watt-hour rating, contact the manufacturer.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

http://www.danielstraining.com/

Are you done?  Not nearly!  But now you can start.  From here the challenge is to comply with the applicable packing instructions for each battery type, configuration, and size by each mode of transportation.

Please contact me if you have any questions about the classification, packaging, labels, markings, and shipping papers for consignments of lithium batteries.