The International Air Transport Association (IATA) is an organization of air carriers that regulates the worldwide transportation of people and property.  IATA’s regulations pertaining to the transportation by air of dangerous goods (hazardous materials or HazMat within the U.S.) is known as the Dangerous Goods Regulations or DGR.  The IATA DGR is updated annually; a new edition becomes effective January 1, 2015.  Though not directly authorized by its regulations. the PHMSA/USDOT accepts compliance with the IATA DGR within the U.S. as compliance with its Hazardous Material Regulations (HMR).  There are changes to the HMR scheduled to take affect in April of 2015 that will harmonize it with the IATA DGR, creating compatibility between these regulations for air transport of lithium batteries within the U.S. and internationally.

The correct transportation of any dangerous good requires the following:

1. Identify the substance or article
2. Classification of the dangerous good.
3. Determination of packaging instructions.
4. Identification of available packaging exceptions.
5. Identification and use of required labels, markings, and the shipping paper.

Substance or article offered for transportation by air by Micro Q Technologies:

Lithium ion battery contained in equipment (e.g. cell phone, camera, lap top computer)

Battery specs: Single Battery consist of 25 cells of 3.7 Volt 2.6 amp hour ( 9.62 watt ) 18650 lithium ion cells configured 5 in series to achieve 18.5 Volts and 5 in parallel to achieve 13 amp hours, total battery power in watts 18.5 V x 13 amp hour = 240 watts

Classification:

UN/ID no.:  3481

Proper Shipping Name/Description:  Lithium ion batteries contained in equipment (including lithium polymer batteries)

Class or Div. (Sub Risk):  9 MISCELLANEOUS

Packing Group: PGII

Packaging:

• Not eligible for the following packaging exceptions:
  • Excepted Quantity
  • Limited Quantity
• Maximum net quantity/package if transported by passenger aircraft = 5 kg
• Maximum net quantity/package if transported by cargo aircraft = 35 kg
• Packaging Instructions by passenger and cargo aircraft = 967

Special Provisions of column M:

• A48 – Packaging tests are not considered necessary.
• A99 – Maximum net quantity/package by cargo aircraft may exceed 35 kg if approved by PHMSA/USDOT.
• A154 – Damaged batteries are forbidden for air transport.
• A164 – Special packing requirements if potential for dangerous evolution of heat.
• A181 – If “batteries contained in equipment” are packaged with “batteries packed with equipment” must be identified as “batteries packed with equipment”.  Must identify lithium ion batteries and lithium metal batteries separately if packaged together.  However, button cell batteries installed in equipment need not be considered.
• A185 -Vehicles only powered by lithium metal batteries or lithium ion batteries must be shipped as UN 3171, Battery-powered vehicle.

Packaging Instructions 967:

• Operator variations for FedEx or UPS are not present or don’t apply.  Other Operator variations are present.
• No State variation identified.
• PI 967 applies to lithium polymer cells & batteries contained in equipment (UN3481) for both passenger and cargo aircraft.
• There are three sections to PI 967 that must be considered:
  • General Requirements apply to all lithium ion cells & batteries contained in equipment prepared for transport according to PI 967
  • Section I applies if the equipment contains lithium ion cells of >20 Wh or lithium ion batteries of >100 Wh.  These must be shipped as a Class 9 MISCELLANEOUS dangerous good.
  • Section II applies if the equipment contains lithium ion cells of ≤20 Wh or lithium ion batteries of ≤100 Wh.

The lithium ion batteries of Micro Q Technologies have a Watt-hour rating of 240 Wh.  Therefore the General Requirements and Section I of PI 967 are applicable; whereas the requirements of PI 967 Section II do not apply.

General Requirements:

• Cells and batteries must be manufactured under a quality management program as described in 3.9.2.6(e) of the IATA DGR.
• Cells and batteries that are damaged, defective, or that can produce dangerous heat or fire are forbidden from air transport.  e.g. cells and batteries returned to the manufacturer for safety reasons.
• Cells and batteries must be protected so as to prevent short circuits.
• Equipment must be equipped to prevent accidental activation.
• Equipment containing lithium ion batteries must be packed in strong outer packaging per 5.0.2.4, 5.0.2.6.1, and 5.0.2.12.1 of the IATA DGR.
• Equipment containing lithium ion cells or batteries must be secured within the outer packaging and packed so as to prevent accidental operation during air transport.

Section I:

• Each cell or battery must comply with 3.9.2.6 of the IATA DGR (summarized below).
• Equipment must be packed in strong outer packagings, such as:
  • Drums:  steel, aluminum, plywood, fiber, plastic, or other metal.
  • Jerricans:  steel, aluminum, or plastic.
  • Boxes:  steel, aluminum, wood, plywood, reconstituted wood, fiberboard, plastic, or other metal.
• Batteries manufactured after December 31. 2011 must have the Watt-hour rating marked on the outside case.

There are no other packaging exceptions available for Lithium ion batteries contained in equipment under PI 967.

Section II:

• If packaged per Section II, lithium ion cells and batteries are not subject to the remainder of the IATA DGR, except for the following:
  • Limits on dangerous goods in passenger and crew baggage.
  • Limits on dangerous goods in air mail.
  • Reporting of dangerous goods accidents, incidents, and other occurrences.
• Cells and batteries must meet provisions of 3.9.2.6(a) and (e).
• Some devices (eg. radio frequency identification tags, watches, and temperature loggers) if not capable of generating dangerous heat may be transported when intentionally active.  If active, must meet defined standards for electromagnetic radiation.
• Equipment must be packed in strong outer packagings.  Type of packaging is not specified as it is for Section I.
• If package contains >4 cells or >2 batteries, then must be labelled with the Lithium Battery Handling Label.  button cell batteries installed in equipment are not counted towards the battery threshold.
  

  Question:  “Answer to question G at the bottom of page 19 and followed on page 20 (IATA Lithium Battery Guidance Document, Revised for the 2014 Regulations) is rather confusing, (number of cells contained inside the lithium Ion battery are NOT counted towards the 4 cell limitation)  Does this mean a loop hole to avoid Class 9?”

  Answer:  No. The exception referred to in question G applies only to the requirement to use the Lithium Battery Handling Label under PI 967 Section II.  Question G also explains that the number of cells in a battery are not counted towards the 4 cell threshold when determining if this exception is available; rather it is the battery itself that is counted.

• A Shipper’s Declaration for Dangerous Goods is not required.
• Each shipment of packages bearing the Lithium Battery Handling Label must be accompanied by a document indicating:
  • The package contains lithium ion cells or batteries.
  • The package must be handled with care.
  • Special procedures to follow if the package is damaged.
  • A telephone number for additional information.
• Each shipment of packages bearing the Lithium Battery Handling Label must include the following on the air waybill, if an air waybill is used (air waybill is not required):  “Lithium ion batteries in compliance with Section II of PI 967”
• Persons preparing cells or batteries for transport must receive adequate instruction on these requirements.

3.9.2.6 of the IATA DGR:

• Each cell or battery must be tested per the UN Manual of Tests and Criteria Part III Subsection 38.3.
• Each cell and battery must incorporate a safety venting device or be designed to preclude a violent rupture under conditions normally incident to transport.
• Each cell and battery must be equipped with an effective means of preventing external short circuits.
• Each battery containing cells or series of cells connected in parallel must be equipped with effective means as necessary to prevent dangerous reverse current flow (e.g., diodes, fuses, etc.).
• Cells and batteries must be manufactured under a quality management program specified at 3.9.2.6(e).  In-house quality management programs may be accepted.

 Requirements of the HMR:

The following are requirements of the HMR that are not found in the IATA DGR; they apply to the transportation of any hazardous material within the U.S.  There are no other requirements of the HMR that will impact the shipment of this HazMat/dangerous good.

• Emergency response information
• HazMat Employee training
• HazMat Security
• HazMat incident reporting
• For export only:
  • General packaging requirements
  • Requirements for reuse of packaging
• Registration as shipper or carrier.

 Conclusion:

The lithium ion batteries contained in equipment (UN 3481) of the Watt-hour rating you describe must be shipped as a Class 9 MISCELLANEOUS dangerous good per the IATA DGR.  The General Requirements and Section I of Packaging Instructions 967 (PI 967) must be followed for its packing.  No packaging exceptions are available for this dangerous good in transportation.

Disclaimer:

This document represents my interpretation of the IATA DGR (2015, 55th Edition) based on the information provided by Micro Q Technologies.  It is meant to be a summary of the main features of the applicable regulations and is not a complete re-statement of them.  As the Shipper of a HazMat/Dangerous Good, you must ensure compliance with the applicable Federal and International regulations.  Please confirm all of the information presented here through your own thorough review of the IATA DGR and the HMR.