An email received March 21, 2022:
Good Afternoon Daniel
I am inquiring in regards to the labelling using UN3481. We have a product that requires the UN3481 but also instructed us to use the attached label “Cargo Aircraft Only”. It is my understanding that this label is only for UN3090 & UN3091.. This is a charger for phones, attached is the MSDS sheet. Can you possibly let me know if we are to use the Cargo Aircraft only? Our plan is to ship via USPS, FedEx and/or UPS.
Can you possibly provide some insight on this?
Again question is do we need to apply the Cargo Aircraft Only sticker, or can we just apply the UN3481
Note: The attached safety data sheet (SDS) indicated the Watt-hour rating is 11.55 Wh. A battery with this Wh rating is eligible for an exception from full regulation for “small” lithium batteries at 49 CFR 173.185(c).
My reply:
I can assist you. It is possible the CAO label is required depending on how the battery is classified and packed. Please confirm or correct the following:
- Is this for a UN3481, Lithium ion battery contained in equipment or UN3481, Lithium ion battery packed with equipment?
- What is the mode of transport: Highway, rail, vessel, or air?
- What is the Watt hour (Wh) rating for the battery?
- What is the net quantity of lithium battery in each package?
- How many lithium batteries will be in each package?
With the above information I will be better able to answer your question.
Note: Answers to some of the questions I asked may not be necessary. However, when classifying lithium cells or batteries for transportation I have found it better to have too much information than too little.
Read: Classification of Lithium Batteries for Transportation in Commerce
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Contact me with any questions you may have about the transportation of lithium batteries by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |
Questioner:
So this is a power bank. Method of transportation: USPS-priority/first class, or UPS/FedEx Ground.. I didn’t think we could ship air?
It can be from 1 to 4 power banks. Varies on the purchase.
Note: Their answer, “So this is a power bank.” led me to believe that the correct classification was not UN3481, Lithium ion battery contained in equipment or UN3481, Lithium ion battery packed with equipment. Instead, I now suspect the correct classification is UN3480, Lithium ion battery, which is a lithium ion battery packed alone. I needed to clarify this before I could proceed to answer their question.
Daniels Training Services:
Please clarify my understanding, which of the following classifications applies to this battery:
- UN3481, Lithium ion battery contained in equipment
- UN3481, Lithium ion battery packed with equipment
Or…
- UN3480, Lithium ion battery (lithium ion battery packed alone).
Questioner:
Yes it is packed alone.. i agree it should be un3480 but we are being told it is un3481 which is what we don’t understand.
Daniels Training Services:
With that clarification I was now able to provide them with the information they required.
Please see below for a summary of the regulatory requirements based on the available information. I am providing information solely for transport by ground within the U.S. subject to USDOT/PHMSA regulations for commercial carriers (FedEx, UPS). I am not considering transport by USPS. (I find their regulations confusing and many postal personnel do not know them properly resulting in confused shipping).
These batteries may be transported by air anywhere in the world subject to the regulations of the International Air Transport Association (IATA). I am familiar with the IATA Dangerous Goods Regulations but they are not considered here. Learn more about ICAO & IATA.
- Classification per USDOT/PHMSA: UN3480, Lithium ion battery, 9
- Shipper must comply with the general packing requirements at 49 CFR 173.185(a) and (b).
- Based on the Wh rating (11.55 Wh) it is eligible for the packaging exception at 49 CFR 173.185(c).
- The package must display the lithium battery mark. The mark must display the ID # “UN3480” in characters at least 12 mm high and an information phone number.
- The package must also display some form of hazard communication indicating it is forbidden as cargo on passenger aircraft. Options for this hazard communication are limited to one of the following:
- “LITHIUM ION BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”
Or…
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- Display the “CARGO AIRCRAFT ONLY” label.
- It seems strange, but even when transportation is entirely by ground, one of the above hazard communication methods must be displayed on the package if it is a lithium cell or battery (packed alone) and is transported subject to the “small” lithium battery exception at §173.185(c).
- It seems stranger, but if this lithium cell or battery was not transported subject to the “small” lithium battery exception at §173.185(c) and instead was transported as a fully-regulated lithium cell or battery, then hazard communication indicating it is forbidden for transport as cargo on passenger aircraft is only required if transport is by aircraft.
- Package must not exceed gross weight of 30 kg (66 lb).
- There are additional packing requirements at §173.185(c)(2).
I hope this helps.
I can provide further assistance under my consulting services or I can provide HazMat Employee training.
Please contact me with any other questions.
They had one more question:
One more question, so if it is determined that it is a UN3480 Powerbank based on the watts/hr it would it require the CAO label going ground fedex or UPS?
My reply:
Not exactly.
A lithium cell or battery, packed alone classified as UN3480, Lithium ion battery, 9, and eligible for the “small” lithium battery exception at §173.185(c) must display some form of hazard communication indicating it is forbidden as cargo on a passenger aircraft. Hazard communication options are limited to one of the following:
- “LITHIUM ION BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”
Or…
- Display the “CARGO AIRCRAFT ONLY” label.
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That did it!
The regulations for the transportation of lithium cells or batteries are complex and seem to become more stringent every year. Of special concern to the regulatory agencies is ensuring lithium cells or batteries of any size packed alone are kept from the cargo hold of passenger aircraft. This is the reason why the requirements for hazard communication that indicate a lithium cell or battery is forbidden for transport aboard passenger aircraft are so strict. Sometimes – as in this case – the requirement to indicate a consignment is forbidden as cargo on passenger aircraft applies even when transportation is by ground.