The Bullet:
Lithium metal batteries transported as cargo will be restricted to Cargo Aircraft Only from 1 January 2015. The prohibition on the carriage on passenger aircraft only applies to lithium metal batteries when shipped by themselves, and does not apply to batteries packed with equipment or contained in equipment.
Check with your carrier to see if they require compliance with the IATA DG Code
Who:
ICAO: International Civil Aviation Organization. A United Nations organization whose regulatory authority over the international transportation of dangerous goods is recognized by the USDOT/PHMSA at 49 CFR 171.24 for domestic compliance.
IATA: International Air Transport Association. A creation of the airline industry as a simplified version of the ICAO Technical Instructions. Required by most air carriers in the world, including those in the US. Though its regulations are not officially recognized for domestic compliance by the USDOT/PHMSA, since its regulations are based on – and in some cases more strict than – the ICAO Technical Instructions, compliance with the IATA DGR is seen as compliant with ICAO for both international and domestic transportation.
You must identify the type of lithium battery and how it is to be transported.
What:
- Lithium ion batteries (rechargeable, also called Li-ion)
- Lithium metal batteries (often non-rechargeable)
- Cargo Aircraft. Any aircraft, other than a passenger aircraft, which is carrying goods or property.
- Passenger Aircraft. An aircraft that carries any person other than a crew member, an operator’s employee in an official capacity, an authorized representative of an appropriate national authority or a person accompanying a consignment or other cargo.
It is important to note that this announced ban only applies to lithium metal batteries being transported as cargo on passenger aircraft.
Also, the prohibition only applies to lithium metal batteries when shipped by themselves. The prohibition does not apply to the following:
- Lithium metal batteries packed with equipment.
- Lithium metal batteries contained in equipment.
Where:
ICAO Technical Instructions must be complied with for air transport outside of the US. Compliance with the IATA DG Code will likely be required by any air carrier you use for both international and domestic transportation.
When:
Announced by ICAO April 16, 2014.
Unless the decision is overturned by the Air Navigation Council or the ICAO Council, the ban will become effective January 1, 2015.
Why:
Numerous fires caused by lithium batteries while being transported by air have proven a challenge to fire suppression and airline safety systems for over a decade.
How:
As noted above, the USDOT/PHMSA, through its acceptance of the ICAO Technical Instructions for compliance with domestic regulations, permits compliance with the IATA DG Code as substitute for compliance with its HMR. It is likely that your carrier will require compliance with the IATA DG Code as a condition of accepting your HazMat for Transportation.
For More Information:
- The IATA Lithium Battery Update for 2015
- IATA Lithium Battery Shipping Guidelines
- IATA Website: Lithium Batteries
- USDOT/PHMSA Guidance: Shipping Batteries Safely by Air – What you need to know
Conclusion:
The IATA Dangerous Goods Code is – in many ways – similar to the Hazardous Material Regulations of the USDOT/PHMSA. However, there are some differences, one of them is the requirement to train personnel involved in the transport of dangerous goods/hazardous materials. If subject only to the domestic regulations of the USDOT/PHMSA, then you must provide initial training (within 90 days of employment) and a full training course every three years. If shipping dangerous goods by air, the IATA DG Code requires training before personnel engage in regulated activities and recurrent training within 24 months.
I can provide all the training required to ship hazardous materials/dangerous goods both domestically and internationally. Contact me for a free training consultation.
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