Happy
New Year to all our customers and website visitors.
New U.S. Requirements
for Non-Regulated Lithium Batteries:
History:
Lithium batteries have been around for a long time. Originally they
were classified as a Flammable Solid (Division 4.1), with a sub-risk
of Dangerous When Wet (Division 4.3). Any amount of this material required
a label as well as a placard on vehicles within the United States. A
U.S.D.O.T. exemption was also required. By air, even under the exemption,
the batteries were forbidden on passenger-carrying aircraft. Very strict
packaging requirements were required.
As the battery
industry developed better manufacturing standards and improved quality
control testing procedures certain relaxations in the regulations occurred
- they were assigned to Division 4.3, no sub-risk was assigned, and
provisions were added allowing very small batteries to be excepted from
the regulations under certain circumstances. Very strict packaging requirements
and quantity limitations continued to prevail, even for the so-called
non-regulated lithium batteries.
As the U.S. D.O.T.
worked diligently with its United Nations harmonization efforts lithium
batteries were reclassified one more time to Class 9. Non-regulated
status remained for the small batteries containing very small quantities
of lithium. Perhaps the use of Class 9 has encouraged people to think
it is hardly worth their attention.
As time has gone
by, the so-called non-regulated (small) batteries increasingly became
involved in transportation accidents and incidents. Although mishandling
appears to be the prime culprit, it appears that safe packaging techniques
seemed to take a back seat to economies in packaging, maybe not so much
by the manufacturer, but by the shippers (distributors may be a better
description) and forwarders.
By virtue of this
prevailing cavalier attitude in handling and repackaging the number
of incidents has increased - fires and near fires and a few explosions
- causing the National Safety Board and the DOT Research and Special
Programs Administration to re-visit their positions regarding the so-called
small, non-regulated batteries.
Through voluntary
efforts within the lithium battery industry, RSPA, and the US FAA new
rules have been implemented governing the non-regulated lithium batteries.
A portion of the RSPA announcement follows. Where appropriate, we have
used bold print to highlight some important requirements.
(Effective 1
February 2001)
Each shipment of covered products that is originated by a participating
company and contains more than 20 new primary lithium cells or 10
new primary lithium batteries will be marked to identify its content
and recommended response actions in the event of an accident or damage
to packaging. The text will appear in both English and the language
of the shipment's origin, and will state ``Lithium batteries inside.
Do not damage or mishandle this package. If package is damaged or mishandled,
batteries must be quarantined, inspected, and repacked.'' The label
will include a toll free number to call in the event of an emergency.
Each shipment of
covered products that is originated by a participating company and contains
more than 40 new lithium ion or lithium polymer cells or more than
20 new lithium ion or lithium polymer multi-cell battery packs (regardless
of the number of cells in each) will carry a label explicitly identifying
its content and recommended response actions in the event of an accident
or damage to packaging. The text will appear in both English and
the language of the shipment's origin, and will state "Lithium
ion rechargeable batteries inside. (No lithium metal.) In the event
of fire, use Class B or C extinguisher. If package is damaged or mishandled,
batteries must be quarantined, inspected, and repacked."
Packages which
are marked will not exceed 30 kg and will be UN 4G fiberboard boxes,
at the Packing Group II performance level, or equivalent.
Participating companies
will provide to air carriers, freight forwarders and other shippers
involved in the air transportation of covered products brochures or
similar documents that describe the covered products and packages, the
physiochemical characteristics of covered products, the communications
program, and safe shipment handling procedures for covered packages.
Issued in Washington,
DC, on August 30, 2000.
Robert A. McGuire,
Associate Administrator for Hazardous Materials Safety.
[FR Doc. 00-22838 Filed 9-6-00; 8:45 am]
BILLING CODE 4910-60-P
We would like to
point out that both regulated and non-regulated batteries are forbidden
in transportation if the batteries are packaged in such a manner that
they may cause a short circuit or buildup of heat. During WW II there
was a famous motto: "Loose Lips Sink Ships". Perhaps in 2001
we should adopt the phrase "Loose batteries cause accidents".
