The Quick Answer:

Adequate instruction is an alternative to full regulatory training for persons who prepare certain lithium cells or batteries for transport by aircraft. The requirement to provide adequate instruction is found in the applicable packing instructions of the IATA Dangerous Goods Regulations.

Summary:

Section II of the lithium battery packing instructions, PI 966, PI 967, PI 969, and PI 970, include a requirement that “Any person preparing or offering cells or batteries for transport must receive adequate instruction on these requirements commensurate with the functions for which they are responsible”. The packing instructions however do not define or describe what is considered as “adequate instruction”.

At 1.6.2 the IATA Dangerous Goods Regulations identifies what – at a minimum – an employer should consider as “adequate instruction”.

A Little Background:

• The Dangerous Goods Regulations of the International Air Transport Association (IATA) are the standard used by the world’s commercial airlines for the transportation in commerce of dangerous goods by air.
• Unless excepted, any person who prepares a dangerous good for transport by air must receive initial and biennial dangerous goods training.
• Lithium cells and batteries of all types, sizes, and packing arrangements are subject to some regulation by IATA as a dangerous good.
• Lithium cells and batteries with higher lithium content are classified as Section I or IA.
• Lithium cells and batteries with a lower lithium content but packed by themselves, i.e., not with or in the equipment they are meant to power are Section IB.
• Lithium cells and batteries with a lower lithium content are classified as Section II and are eligible for an exception from full regulation.
• The packing instructions correspond to the following battery types:
  • PI 966 – Lithium ion cell or battery packed with – but not contained in – the equipment it is meant to power.
  • PI 967 – Lithium ion cell or battery contained in the equipment it is meant to power.
  • PI 969 – Lithium metal cell or battery packed with – but not contained in – the equipment it is meant to power.
  • PI 970 – Lithium metal cell or battery contained in the equipment it is meant to power.

The Regulations:

• The requirement to provide adequate instruction is found in the Section II of the applicable packing instructions in the IATA Dangerous Goods Regulations.
• The minimum requirements for adequate instruction are identified at 1.6.2 of the IATA Dangerous Goods Regulations and detailed below:
  • Classification of lithium batteries being shipped.
  • Documentation of procedures applied to lithium batteries being shipped.
  • Written work instructions or other documentation, including automated controls.
  • Review and understanding of documented procedures as applicable to the job function.
  • Instruction records including date(s) for all employees.
  • Refresher instructions provided at a minimum every two years or as the documented instructions are revised or regulations are changed.
  • Reverse logistics, including transport mode and applicable prohibitions.

The Answer:

A lithium cell or battery that is packed with the equipment it is meant to power (e.g., PI 966 or PI 969) or contained in the equipment it is meant to power (e.g., PI 967 or PI 970) and has a lower lithium content (i.e., Section II) is eligible for an exception from full regulation under the IATA Dangerous Goods Regulations when transported by commercial air. Part of this exception allows the employer of persons who pack or ship the Section II lithium cells or batteries to provide them with adequate instruction instead of full IATA Dangerous Goods Training.

Adequate instruction is not defined, but its minimum requirements are identified. Adequate instruction requires the employer to create work instructions specific to the operations of its employees for the classification, packaging, and hazard communication (e.g., marks, labels, shipping paper) of its lithium cells and batteries. These instructions must be communicated to employees initially and renewed at least every two years. Records must be kept of the date(s) instructions were provided to employees.

I may be biased, but I interpret adequate instruction to include some form of training.

Conclusion:

The regulations for the transportation of lithium cells and batteries are complex and subject to change. It should come as no surprise the regulations for transportation by air addressed in this article are more stringent than for other modes. The regulations of the International Maritime Organization (IMO) and the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) do not require training nor adequate instruction for similar sized and packed lithium cells and batteries when transported subject to their regulations.