Q&A: What transport regulations apply to lithium ion batteries in equipment?

Q&A: What transport regulations apply to lithium ion batteries in equipment?

A commonly-shipped HazMat that generates a lot of questions for me:  lithium batteries:

Hello,

I saw that you had answered a few questions about transporting batteries in the past, and I had one for you that I hope you can answer. My company is transporting (by ourselves, not shipping), several manufactured articles over the coming months and they all contain three Li-Ion cells wired series to produce a 12V, 144Wh battery. Do we need any special placards or packaging etc with these on board?

Thank you,

I required a little time to research the regulations but replied a few days later:

Thank you for contacting me.  I will do my best to answer your question below.

  • What you describe will be classified as a hazardous material when offered for transportation as:  UN3481, Lithium ion batteries contained in equipment, 9
  • A lithium ion battery of 144 Wh – while not below the initial threshold of 100 Wh – is subject to the smaller lithium battery exception per 49 CFR 173.185(c)(1)(iv) which has a threshold of 300 Wh.

    Note:

    Batteries used in most consumer products – laptops, phones, power tools – are lithium ion of less than 100 Watt hours.

  • Conditions of this particular exception include:
    • Transport by highway or rail only.
    • Outer packaging must be marked “LITHIUM BATTERIES – FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL”.  The mark must be of a size specified in 173.185(c)(1)(v).
    • Equipment battery is contained in must provide sufficient protection or the equipment must be placed in a rigid outer packaging.
  • No other package marks or labels are required as long as there are no more than two lithium batteries per package and no more than two packages per shipment (consignment).
  • The general packing requirements of 49 CFR 173.185(a)(1) & (2) and 173.185(b)(1) & (2) & (4) apply.
  • No other requirements of the Hazardous Materials Regulations of USDOT apply.

Also…

  • Placards are not required to be displayed on a vehicle transporting any amount of Class 9 Miscellaneous. Curious? read more about the requirement to display the Class 9 placard.
  • Since placards are not required a HazMat endorsement on the driver’s CDL is not required.
  • A CDL may not be required depending on the weight of the vehicle and the type of transportation (interstate v. instrastate).

I hope this helps.

Please don’t hesitate to contact me with any questions.

I didn’t hear back from them so I assume my answer was enough.

There are two points I suggest you take from this article:

  • The bigger the battery – measured in Watt hours for lithium ion and grams of lithium metal for lithium metal – the more burdensome the regulations.
  • The regulations for the transport of lithium batteries are most strict by aircraft, less strict by vessel, and least strict by highway and rail.

And finally: don’t take the transport of lithium batteries lightly! There are regulations (domestic and international) for their transport by all modes (aircraft, vessel, highway, or rail).  Let me help you to navigate your way through them.

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, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/