If you move goods in the U.S., you must be prepared to abide by the Code of Federal Regulations (CFR) Title 49. The Title 49 rules encompass regulations for domestic transportation. Continue reading…
Shippers are concerned with the timely, safe, and affordable transportation of their goods from one place to another. While many shipped goods are safe to handle, hazardous materials transported from country to country pose risks to people and equipment along the way. Continue reading…
Hazardous materials may be daily household objects, from batteries and paints to medical materials and caustic chemicals. Even cosmetics and consumables may be classified as hazardous before final production or in large quantities. Mundane items, such as sunblock, anything in an aerosol spray can, and diving equipment, fall under strict regulations for shipment. Continue reading…
Pipeline and Hazardous Materials Safety Administration’s Notice Regarding the IMDG Code and ICAO Technical Instructions
The U.S Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) understands that many offeroers and carriers of of hazardous materials in international transport are currently adhering to requirements in the recently-adopted 2017-2018 International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICOA Technical Instructions) and Amendment 36-16 of the International Maritime Dangerous Goods Code (IMDG Code). Currently, the Hazardous Materials Regulations (HMR; CFR Parts 171-180) only authorize offerors and carriers to use the 2015-2016 versions of the standards.
PHMSA hereby gives notice that while it decides whether or not to adopt the 2017-18 versions of these international standards, it will not take enforcement action against any offeror or carrier who is using the 2017-2018 versions of these standards when all or part of the transportation is by air with respect to the ICAO Technical Instructions, or all or part of the transportation is by vessel with respect to the IMDG Code. In addition, PHMSA will not take enforcement action against any offeror or carrier who offers or accepts for domestic or international transportation by any mode packages marked or labeled in accordance with the 2017-18 versions. PHMSA will permit the use of either the 2015-2016 standards or the newer standards until this notice is rescinded or otherwise modified. THis enforcement discretion will be exercised by the Federal Aviation Administration, the Federal Motor Carrier Safety Administration, the Federal Railroad Administration, and the Pipline and Hazardous Materials Safety Administration.
This notice is limited to the use of the standards incorporated by reference in 49 C.F.R. 171.7(t) and (v). THis notice does not affect any other obligations that offerors or carriers may have under the HMR or any other applicable law.
Issued Febuary 27, 2017, in Washington, D.C.
Howard W. McMillan
Acting Deputy Administrator
Pipeline & Hazardous Materials
Whenever you receive a container, you can expect to find numerous labels. There’s usually the address of the sender and the recipient, along with some postal markup to indicate if the package was submitted normally or delivered through an express system by request.
If you happen to work with materials that are somewhat dangerous, you are going to see several additional markups that contain information about the product itself, the dangers it may cause to human health, and how it should be properly handled. Continue reading…
Many shipments of time and temperature sensitive products including food, pharmaceutical,medical devices, vaccines, and industrial chemicals such as chemical-mechanical planarization (CMP) slurries, adhesives, and sealants contain, or have attached to the package(s) and/or overpack(s) small battery-powered tracking devices / data loggers. Most of these devices use lithium metal or lithium ion cells or batteries as a power source.
Lithium cells and batteries are classified as dangerous goods and therefore must meet all of the applicable provisions of the Dangerous Goods Regulations (DGR) when shipped by air. This applies regardless of whether the lithium cells or batteries are shipped as cargo in their own right or whether the lithium cells or batteries are installed in a small device such as a data logger that is placed inside or attached to packages of cargo. In addition, to be permitted in transport all lithium cell and battery types must have passed the applicable tests set out in Subsection 38.3 of the UN Manual of Tests and Criteria.
The purpose of this document is to provide guidance on:
1. complying with provisions applicable to the transport by air of lithium batteries as set out inthe DGR when lithium battery powered data loggers are contained in cargo; and
2. recommendations with respect to the use of battery-powered devices that are active during transport. The recommendations for active devices are taken from FAA Advisory Circular AC 21.91-1C, primarily the recommendations in Section 8 of the AC, which relate to active devices carried in the aircraft cargo compartment.
This document is based on the provisions set out in the 2017-2018 Edition of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions) and the 58th Edition of the IATA DGR, Section II of Packing Instructions (PI) 967 and PI 970.
The provisions of the DGR with respect to lithium batteries may also be found in the IATA Lithium Battery Shipping Guidelines (LBSG). In addition to the content from the DGR, the LBSG also has additional classification flowcharts and detailed packing and documentation examples for lithium batteries.
Information on the DGR and LBSG can be found here:
REQUIREMENTS FOR LITHIUM CELLS AND BATTERIES
The extent to which the lithium cells or batteries are regulated as dangerous goods depends on:
(a) the lithium metal content for lithium metal cells or batteries; or
(b) the Watt-hour (Wh) rating for lithium ion cells or batteries.
Fully Regulated Lithium Batteries
Lithium metal cells with a lithium metal content exceeding 1 g and lithium metal batteries with a lithium metal content exceeding 2 g.
Lithium ion cells with a Watt-hour rating exceeding 20 Wh and lithium ion batteries with a Watt-hour rating exceeding 100 Wh.
Devices that contain fully regulated lithium cells or batteries are subject to all of the provisions of the DGR, which includes:
(a) dangerous goods training. All persons involved in the preparation and shipping must have completed appropriate dangerous goods training and must attend recurrent dangerous goods training at intervals not exceeding 24 months;
(b) marks and labels on packages. All packages must be marked with the name and address of the shipper and consignee, the UN number and proper shipping name. Packages must also bear the Class 9 lithium battery hazard label, except that until 31 December 2018 the standard Class 9 miscellaneous hazard label may be used;
(c) documentation. The consignment must be correctly described on a Shipper’s Declaration for Dangerous Goods.
Excepted Lithium Batteries
Where the lithium cells or batteries have a lithium metal content of 1 g or less for cells or 2 g or less for batteries or for lithium ion the cells have a Watt-hour rating of 20 Wh or less or batteries are 100 Wh or less, then they are not subject to all of the provisions of the DGR.
Lithium cells or batteries that fit within these limits are subject to Section II of the applicable lithium battery packing instructions in the DGR. Each package that contains such cells or batteries, including those installed in devices, must not contain more than 5 kg net weight of lithium cells or batteries.
Cargo Tracking Devices/Data Loggers Containing Excepted Lithium cells or Batteries
Packages containing lithium batteries installed in equipment such as a data logger must bear the lithium battery mark as shown in Figure 7.1.C of the IATA DGR, see Figure 1. The border of the label must have red diagonal hatchings 5 mm in width with text and symbols in black on a white or contrasting background. The lithium battery mark may be printed directly on the outer packaging provided that there is sufficient contrast between the elements of the lithium battery mark and the colour of the packaging material. The minimum dimensions are 120 mm wide x 110 mm high.
1. the lithium battery mark is not required on packages where the data loggers are powered by only button (coin) cells (regardless of the quantity of data loggers in a particular package or the number of packages in a consignment);
2. the lithium battery mark is not required on packages where there are no more than 4 cells or 2 batteries contained in equipment in each package and there are no more than two packages in the consignment.
This means that if the cargo tracking device or data logger is powered by other than lithium button (coin) cells and there are more than two packages containing tracking devices/data loggers, then the lithium battery mark must be applies to all packages in the consignment that contain tracking devices/data loggers.
Figure 1 – Lithium Battery Mark
* Place for UN number(s), i.e. UN 3090, UN 3091, UN 3480 and/or UN 3481, as applicable
** Place for telephone number
The lithium battery handling label as shown in the 57th edition of the DGR, see Figure 2, may continue to be used until 31 December 2018.
* Place for “Lithium ion battery” and/or “Lithium metal battery”
Where the packages are of dimensions such that they cannot bear the full size lithium battery mark, the mark dimensions may be reduced to 105 mm wide × 74 mm high. The design specifications otherwise remain the same.
The telephone number on the lithium battery mark (or lithium battery handling label) should be that of a person knowledgeable about the shipment but is not intended to be for the purposes of obtaining immediate emergency response guidance, and is therefore not required to be monitored at all times while the package is in transit. It is acceptable for the number to be monitored during the company’s normal business hours in order to provide product-specific information relative to the shipment. However, it also is acceptable to use an emergency response, 24-hour phone number on the lithium battery mark.
Where a consignment includes packages bearing the lithium battery mark, the words “Lithium ion batteries in compliance with Section II of PI 967” or “Lithium metal batteries in compliance with Section II of PI 970”, as applicable must be included on the air waybill, when an air waybill is used. The information should be shown in the “Nature and Quantity of Goods” box of the air waybill.
A Shipper’s Declaration for Dangerous Goods is not required.
Shippers of excepted lithium batteries are not subject to the formal dangerous goods training requirements set out in DGR 1.5, however, persons preparing such shipments must be provided with “adequate instruction” as described in DGR 1.6.
The following is offered as a starting point for an employer on what could be considered as being adequate instruction:
1. The employer must identify the different configurations of lithium batteries that they ship, i.e. lithium batteries and/or lithium batteries packed with equipment and/or lithium batteries contained in equipment; lithium metal batteries and/or lithium ion batteries.
2. The employer must document the procedures that apply to the configurations and battery types that they ship as determined in 1, above.
3. The procedures should be written up as a clear work instructions or other form of information that is available to all employees responsible for the preparation of lithium battery shipments.
4. All employees that are involved in the process of preparing lithium battery shipments must be taken through the procedure to ensure that they understand and can demonstrate the correct application of documented procedures for the packing, labelling, marking and documentations requirements, as applicable to their job function.
5. A record must be maintained that identifies each applicable employee and the date(s) that this instruction was provided.
6. Employees should be given periodic refresher, or at least demonstrate that they remain “adequately” instructed on how to perform the task. This should be done at least every two years or whenever the procedure is revised, or regulations are changed, whichever is sooner.
7. Companies that are involved in reverse logistics, i.e. arranging for returns of lithium batteries, lithium batteries packed with equipment or lithium batteries contained in equipment must develop a clear instruction for consumers on the process to be followed for returning products. This instruction must include packaging materials and lithium battery marks, as necessary. The instruction must also include the transport method and mode of transport to be followed; this must include a clear statement on applicable prohibitions.
RECOMMENDATIONS ON SHIPPING ACTIVE DEVICES
Portable electronic devices (PED) such as data loggers and cargo tracking devices, that are designed to remain active throughout their entire transport from the shipper to the consignee, including when on board an aircraft, have the potential to interfere with aircraft navigation or communication systems.
Therefore, manufacturers of PED, users of PED and the operator (airline) are only permitted to place in or attach to cargo and to carry PED that the operator of the aircraft has determined will not interfere with the safe operation of that aircraft. The recommendations set out in this document are one means, but not the only means, of complying with the applicable operational regulations pertaining to the operation of PED.
This section applies to PED that are designed for use on aircraft in locations inaccessible to the flight crew during flight. Because this class of PED cannot be turned off manually in the event of an emergency, the device manufacturers and aircraft operators must ensure certain design and operational considerations are addressed. The operator must ensure that these PED meet the following criteria prior to allowing use on aircraft:
1. the cargo tracking device/data logger meets the RF radiated emissions limits defined in RTCA/DO-160, Environmental Conditions and Test Procedures for Airborne Equipment, Section 21, Category H during all modes of operation. Testing of the device must include any peripheral devices that will be used with the device during normal operations. Typically, peripherals include external sensors or associated wiring. For additional Guidance, refer to RTCA/DO-357, User Guide: Supplement to DO-160G.
2. the device is designed with a minimum of two independent means to turn off completely, turn off cellular or mobile functions, or a combination of both when airborne. These independent methods must use different sources to identify flight. For example, a cargo tracking device designed to sense rapid altitude changes and acceleration to turn off cellular transmissions is an acceptable design feature that meets the requirement. Redundant sources of the same information, such as two vertical accelerometers, would not be an acceptable design.
3. the device manufacturer substantiated data includes:
(a) pictures of the device and any peripherals,
(b) product label,
(c) operational description of device and peripherals,
(d) manufacturer statement of strict design and production controls, and
(e) if device contains a lithium battery, battery design standard and relevant battery qualification documentation (e.g., TSO-C142a, Non-Rechargeable Lithium Cells or Batteries, dated August 7, 2006, approval; RTCA/DO-311, Minimum Operational Performance Standards for Rechargeable Lithium Battery Systems, dated March 13, 2008, qualification report, maintenance requirements and process and procedures to address the movement of defective devices, including damaged or defective batteries).
4. the device must not be capable of generating a dangerous evolution of heat.
5. the device must not be capable of emitting disturbing signals, such as buzzing alarms or strobe lights, during transport.
Manufacturers of cargo tracking devices/data loggers should undertake all of the required testing of their devices so that they can satisfy the aircraft operator that the devices comply with the recommendations above. It is recommended that the device manufacturers coordinate with the aircraft operators so that a list of approved devices is available to users of the devices.
It is the operator that retains the responsibility to approve the use and carriage of PED in cargo and it is the operator that will issue any authorisation or approval on the use of PED on their aircraft.
It is recommended that manufacturers of PED that are intended to be placed into, or attached to cargo make contact with operators in advance so that the approval / authorisation can be coordinated. This will avoid the need for multiple individual shippers to seek approval / authorisation for the same device.
Lithium Battery – The term “lithium battery” refers to a family of batteries with different chemistries, comprising many types of cathodes and electrolytes. For the purposes of the DGR they are separated into:
Lithium metal batteries. Are generally primary (non-rechargeable) batteries that have lithium metal or lithium compounds as an anode. Also included within lithium metal are lithium alloy batteries. Lithium metal batteries are generally used to power devices such as watches, calculators, cameras, temperature data loggers, car key fobs and defibrillators.
Lithium metal batteries packed by themselves (not contained in or packed with equipment) (Packing Instruction 968) are forbidden for transport as cargo on passenger aircraft) unless shipped under exemption issued by all States concerned, see Special Provision A201.
Figure 1 – Example of Lithium Metal Cells and Batteries
Lithium-ion batteries (sometimes abbreviated Li-ion batteries) are a secondary (rechargeable) battery where the lithium is only present in an ionic form in the electrolyte. Also included within the category of lithium-ion batteries are lithium polymer batteries. Lithium-ion batteries are generally used to power devices such as mobile telephones, laptop computers, tablets, power tools and e-bikes.
Figure 2 – Example of Lithium Ion Cells and Batteries
Lithium ion batteries packed by themselves (Packing Instruction 965) (not contained in or packed with equipment):
(a) must be shipped at a state of charge (SoC) not exceeding 30% of their rated design capacity. Cells and/or batteries at a SoC of greater than 30% may only be shipped with the approval of the State of Origin and the State of the Operator under the written conditions established by those authorities, see Special Provision A331; and
(b) are forbidden for transport as cargo on passenger aircraft unless shipped under exemption issued by all States concerned, see Special Provision A201.
The technical definition of a battery and cell, as indicated in the UN Manual of Tests and Criteria, is as follows:
Battery means two or more cells which are electrically connected together and fitted with devices necessary for use, for example, case, terminals, marking and protective devices. Units which have two or more cells that are commonly referred to as “battery packs”, “modules” or “battery assemblies” having the primary function of providing a source of power to another piece of equipment are for the purposes of the UN Model Regulations and this guidance document treated as batteries. See definitions for “cell” and “single cell battery”. (See also “Power Banks”)
Button cell or battery means a round small cell or battery when the overall height is less than the diameter.
Cell means a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Under the UN Model Regulations, UN Manual of Tests and Criteria and this guidance, to the extent the encased electrochemical unit meets the definition of “cell” herein, it is a “cell”, not a “battery”, regardless of whether the unit is termed a “battery” or a “single cell battery” outside of the UN Model Regulations, the UN Manual of Tests and Criteria and this guidance.
Consignment, one or more packages of dangerous goods accepted by an operator (airline) from one shipper at one time and at one address, receipted for in one lot and moving to one consignee at one destination address.
Operator, a person, organisation or enterprise engaged in or offering to engage in an aircraft operation.
Overpack, an enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the overpack must be properly packed, marked, labelled and in proper condition as required by the DGR. (A Unit Load Device is not included in this definition).
Package, (for dangerous goods) the complete product of the packing operation consisting of the packaging and contents prepared for transport.
Packaging, one or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions and to ensure compliance with the minimum packing requirements of the DGR.
Unit Load Device (ULD), any type of freight container, aircraft container, aircraft pallet with a net, or aircraft pallet with a net over an igloo.
An overpack is not included in this definition.
Watt-hour Rating, expressed in Watt-hours (Wh), the Watt-hour rating of a lithium cell or battery is calculated by multiplying the rated capacity in ampere-hours by the nominal voltage.
FREQUENTLY ASKED QUESTIONS
Part 1 – Questions Related to Definitions
A. What are the various types of lithium batteries?
Lithium batteries fall into two broad classifications; lithium metal batteries and lithium ion batteries. Lithium metal batteries are generally non-rechargeable and contain metallic lithium. Lithium ion batteries contain lithium which is only present in an ionic form in the electrolyte and are rechargeable.
Within these two broad classifications there are many different chemistries. For example within lithium ion batteries there are lithium polymer, lithium iron phosphate (LiFePO4), lithium air to name a few.
B. What is the difference between a lithium cell and a lithium battery?
A lithium cell is a single encased electrochemical unit consisting of one positive and one negative electrode that exhibits a voltage differential across the two terminals. A lithium battery is two or more cells electrically connected. A single cell battery is considered a cell and not a battery for the purposes of the limitations set out in the DGR.
Note: Units that are commonly referred to as “battery packs” or “power banks” having the primary function of providing a source of power to another piece of equipment are for the purposes of these Regulations treated as batteries. Refer to the section on Definitions for complete details.
C. How are component cells connected to form a battery?
Cells in batteries may be connected in parallel, in series, or in a combination of the two. When cells are connected in series, the voltage of the battery increases but the capacity in ampere-hours (Ah) does not change. By contrast, when cells are connected in parallel the capacity in ampere-hours of the battery (Ah) increases but the voltage stays the same.
D. How do I determine the watt-hour rating for a particular lithium ion battery?
The watt-hour (Wh) rating is a measure by which lithium ion batteries are regulated. Section I Lithium ion batteries manufactured after 31 December 2011 and Section IB and Section II Lithium ion batteries manufactured after 1 January 2009 are required to be marked with the watt-hour rating.
You can also arrive at the number of watt-hours your battery provides if you know the battery’s nominal voltage (V) and capacity in ampere-hours (Ah):
Ah x V = Wh
If only the milliampere-hours (mAh) are marked on the battery then divide that number by 1000 to get ampere-hours (Ah) (i.e. 4400 mAh / 1000 = 4.4. Ah).
Most lithium ion batteries marketed to consumers are below 100 watt-hours. If you are unsure of the watt-hour rating of your lithium ion battery, contact the manufacturer.
E. What is a button cell battery?
A button cell battery is a round small cell where the overall height is less than the diameter. Button cells are often referred to as “coin” cells.
Part 2 – Questions Related to Design Type Testing Provisions
A. Where can I find requirements related to testing of battery design types?
The UN Manual of Tests and Criteria sets out specific tests that must be conducted on each lithium cell or battery design type. Each test is intended to either simulate a common transportation occurrence such as vibration or changes in altitude or to test the integrity of a cell or battery. You may obtain a copy of these testing requirements via the following website: http://www.unece.org/trans/danger/publi/manual/manual_e.html.
B. What constitutes a design change requiring renewed design type testing?
The following provisions are taken from the 6th revised edition of the UN Manual of Tests and Criteria, paragraph 18.104.22.168.
A cell or battery that differs from a tested design by:
(a) For primary cells and batteries, a change of more than 0.1 g or 20% by mass, whichever is greater, to the cathode, to the anode, or to the electrolyte;
(b) For rechargeable cells and batteries, a change in Watt-hours of more than 20% or an increase in voltage of more than 20%; or
(c) A change that would materially affect the test results.
shall be considered a new type and shall be subjected to the required tests.
Note: the type of change that might be considered to differ from a tested type, such that it might lead to a failure of any of the test results, may include, but is not limited to:
(a) A change in the material of the anode, the cathode, the separator or the electrolyte;
(b) A change of protective devices, including the hardware and software;
(c) A change of safety design in cells or batteries, such as a venting valve;
(d) A change in the number of component cells;
(e) A change in connection mode of component cells;
(f) For batteries which are to be tested according to T.4 with a peak acceleration less than 150 gn, a change in the mass which could adversely impact the result of the T.4 test and lead to a failure.
In the event that a cell or battery type does not meet one or more of the test requirements, steps shall be taken to correct the deficiency or deficiencies that caused the failure before such a cell or battery type is retested.
C. Who is responsible for testing lithium cells and batteries?
It is the manufacturer of the lithium cell type to have the type tested against the applicable provisions set out in Subsection 38.3 of the UN Manual of Tests and Criteria. In addition where lithium cells are combined together to form a battery, the manufacturer of the lithium battery must have the battery type tested against the applicable provisions set out in Subsection 38.3 of the UN Manual of Tests and Criteria.
Manufacturers of devices that incorporate lithium cells or batteries should seek confirmation from the manufacturer or supplier of the lithium cells or batteries that the cell or battery type has passed the applicable UN 38.3 tests.
Part 3 – Questions related to Packaging and Transport Provisions
A. If I have smaller packages, can I use a smaller lithium mark?
Where the packages are of dimensions such that they cannot bear the full size lithium battery mark, the mark dimensions may be reduced to 105 mm wide × 74 mm high. The design specifications remain otherwise the same.
B. When is a lithium battery mark not required on the package?
A lithium battery mark is not required for packages prepared in accordance with Section II of PI 967 or PI 970 containing only button cell batteries installed in equipment (including circuit boards) or consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.
The Air Waybill is only required to contain the statements “Lithium [ion or metal] batteries in compliance with Section II of PI9XX” when the lithium battery mark is affixed to the package(s).
C. Section II in Packing Instructions 967 and 970 states that “the lithium battery mark is not required on consignments of two packages or less where each package contains no more than four cells or two batteries installed in equipment.” What is the intent of this provision?
This provision is to require, where there are more than two packages in the consignment, that each package bears the lithium battery mark, and therefore the air waybill has the compliance statement e.g. “Lithium [ion or metal] batteries in compliance with Section II of PI 9xx [67 or 70]”.
The provision continues to allow for small consignments of one or two packages containing no more than four cells or two batteries installed in equipment per package to move without the lithium battery mark and therefore without the compliance statement on the air waybill.
A consignment is one or more packages of dangerous goods accepted by an operator (airline) from one shipper at one time and at one address, receipted for in one lot and moving to one consignee at one destination address.
D. For the purposes of the lithium battery packing instructions, what is considered the “package”?
The package is the complete product of the packing operation that satisfies the requirements of the packing instruction and in a manner ready to be presented for transport (shipper/consignee information, hazard communication, net quantity of lithium batteries is within limits). The package may contain multiple batteries or pieces of equipment provided the limitations set out in the applicable packing instruction are not exceeded. The package must be marked and labelled as required by the packing instruction.
A “package” may contain multiple boxes that are all placed inside an outer packaging to form a discrete unit for transport provided that the total net quantity of lithium cells or batteries inside the “package” does not exceed 5 kg. Or, one or more packages may then be placed into an overpack for ease of handling or transport purposes. When an overpack is used, the package marks and labels must be duplicated on the overpack unless the marks and labels required on individual packages are visible, or are not required by the packing instruction (i.e. not more than 4 cells or 2 batteries when contained in equipment and no more than two packages in the consignment).
E. Can a single lithium battery mark be used to identify that both lithium metal and lithium ion batteries are contained inside the package?
Yes. The mark may bear all applicable UN numbers, e.g. UN 3091, UN 3481, to identify that the package contains lithium metal batteries packed with, or contained in equipment and lithium ion batteries packed with, or contained in equipment.
F. What are the requirements for the telephone number on the lithium battery mark?
The telephone number should be of a person knowledgeable about the shipment but is not intended to be for the purposes of obtaining immediate emergency response guidance, and is therefore not required to be monitored at all times that the package is in transit. It is acceptable for the number to be monitored during the company’s normal business hours in order to provide product-specific information relative to the shipment. However, it also is acceptable to use an emergency response, 24-hour phone number on the lithium battery mark.
G. Is it acceptable to apply the lithium battery mark to packages that contain only button cells installed in equipment?
Yes, the allowance not to apply the lithium battery mark to packages containing equipment with only button cells is a relaxation from the regulations, not a prohibition. However, if the package(s) bear the lithium battery mark, then the compliance statement must be included on the air waybill, when an air waybill is used.
H. Does IATA require a MSDS or SDS containing the UN test data?
No. IATA does not require a material safety data sheet (MSDS or SDS), or the UN 38.3 test data report as part of the required documentation requirements when offering lithium batteries for transport.
I. May lithium battery packages be placed in an overpack in accordance with the IATA Dangerous Goods Regulations?
Yes. The overpack may also contain packages of dangerous goods or goods not subject to the Regulations provided there are no packages enclosing different substances which might react dangerously with each other. An overpack must be marked with the word “overpack” and must be labelled with the lithium battery mark (DGR Figure 7.1.C), unless the mark(s) on the package(s) inside the overpack are visible or not required by the Packing Instruction.
In addition, the word “overpack” must be marked on overpacks containing packages transported in accordance with Section I of the applicable Packing Instructions (i.e. bearing the Class 9 lithium battery hazard label).
For Section II of PI 965 and PI 968 the shipper is limited to one (1) package per consignment (shipment) and no more than one (1) package complying with the requirements of Section II may be placed in an overpack. This overpack may also contain packages prepared in accordance with Section IA and/or IB of PI 965 and/or PI 968 and/or packages of other dangerous goods and/or packages of non-dangerous goods.
J. Do the quantity limits shown in the lithium battery packing instructions apply to overpacks containing lithium batteries?
The quantity limits shown in the packing instructions refer to the maximum net weight of lithium batteries in each package. Provided each package remains within the limit specified in the packing instruction, there are no limits specified for an overpack.
For Section II of PI 965 and PI 968 the shipper is limited to one (1) package per consignment (shipment) and no more than one (1) package complying with the requirements of Section II may be placed in an overpack. This package may be placed in an overpack. This overpack may also contain packages prepared in accordance with Section IA and/or IB of PI 965 and/or PI 968 and/or packages of other dangerous goods and/or packages of non-dangerous goods.
K. Can I ship recalled, damaged or non-conforming cells or batteries?
Lithium batteries, identified by the manufacturer as being defective for safety reasons, or that have been damaged, that have the potential of producing a dangerous evolution of heat, fire or short circuit are forbidden for transport by air (e.g. those being returned to the manufacturer for safety reasons). This applies also to lithium cells or batteries installed inside equipment such as mobile phones, laptops or tablets where the devices are subject to recall due to the safety concerns of the lithium cell or battery installed in the device.
Batteries which have some other defective feature (e.g. LEDs not showing charge, incorrect model number on label, or batteries not holding enough charge) could still be shipped by air. Also, laptops being returned may not have a defective battery, it may not meet the needs of the customer, may be defective itself (but not the battery), etc. In these situations air transport would be permitted. The battery or equipment manufacturer should be contacted to determine the appropriate shipping method.
L. How do I protect against “inadvertent activation”?
When batteries are contained in equipment, the equipment must be packaged in a manner that prevents unintentional activation or must have an independent means of preventing unintentional activation (e.g., packaging restricts access to activation switch, switch caps or locks, recessed switches, trigger locks, temperature sensitive circuit breakers, etc.). This requirement does not apply to devices which are intentionally active in transport (RFID transmitters, watches, sensors etc.) and which are not capable of generating a quantity of heat sufficient to be dangerous to packaging or personal safety.
M. I am shipping perishable and/or pharmaceutical cargo with lithium battery powered temperature or data loggers do I need to follow the Dangerous Goods Regulations?
Yes. All the applicable provisions for lithium batteries will need to be followed by the shipper of such devices, including the limitations for devices that are active during transport.
N. Does the definition of “consignment” apply to the house air waybill (HAWB) or to the master air waybill (MAWB)?
The use of HAWB or MAWB has no direct relationship to what is a “consignment”. For example a MAWB may have multiple consignments where each of the consignments are from separate shippers, or are from one shipper but to separate consignees, or the MAWB may be just be a single consignment from one shipper to one consignee.
The following limitations apply to consignments:
1. a shipper is not permitted to consign more than one package of Section II, PI 965 or PI 968; and
2. a shipper is not permitted to consign more than two packages of lithium batteries contained in equipment under Section II of PI 967 and PI 970 where there are no more than 4 cells or 2 batteries in the package without the application of the lithium battery handling label (lithium battery mark) on the package.
The objective of these two conditions is to:
1. restrict the number of packages of just lithium batteries that are carried by air that are not subject to the dangerous goods acceptance check and that are not shown on the written information to the pilot-in-command. The intention here is to force shippers of multiple packages to declare these on a Shipper’s Declaration for Dangerous Goods and therefore make the consignment subject to the full checks for air transport.
2. require appropriate hazard communication on packages and on the air waybill where a shipper has more than two packages of lithium batteries contained in equipment.
1. This does not mean that every retail “package” must bear the lithium battery mark. A shipper may place multiple retail boxes, each containing a lithium battery meeting Section II installed in equipment, into an outer packaging to form the package for air transport. There is no limit on the number of individual retail boxes that can be placed into the outer packaging, except that a “package” must not contain more than 5 kg net weight of lithium batteries. Each such package must bear the lithium battery mark and when an air waybill is used the air waybill must show the applicable compliance statement, e.g. “lithium ion batteries in compliance with section II of PI 967”.
2. Shippers or freight forwarders should not try to split a consignment across multiple air waybills to try to avoid the application of the lithium battery mark where there are more than two packages with lithium batteries contained in equipment under Section II in a consignment.
O. Are consignments that contain just Section II lithium batteries subject to a dangerous goods acceptance check by the airline or their ground handling agent?
No, the provisions in the lithium battery packing instructions for Section II do not include the dangerous goods acceptance check as one of the provisions that apply. Any decision on performing an acceptance check of packages that contain Section II lithium batteries is the airlines’. Dangerous goods acceptance are only legally required for fully regulated, Section I lithium batteries.
P. I am placing a data logger inside an aircraft unit load device (ULD) to monitor the temperature during transit. Do I need to place a lithium battery mark on the ULD?
No, If the data logger is not inside a package or overpack, the marking provisions of the DGR do not apply. It is only packages and overpacks that require marks and labels. Shippers must not attach marks and labels to ULD’s.
Further information can be found here:
You may also contact the airline of your choice or your national civil aviation authority if you have any further concerns on the use or carriage of data loggers containing small batteries that are active (on) while in transport.
You can also contact the IATA Dangerous Goods Support team if you have questions or concerns which may not have been addressed in this document: firstname.lastname@example.org
Packaging is one of those things we tend to dismiss as an annoying necessity when products are being shipped by car, airplane, train, or ferry. This is certainly true for people selling or distributing things that are not harmful in any way. The only thing that matters for those individuals is that the product gets there on a timely basis in one piece. As long as this singular condition is met, nothing else really matters. Continue reading…
SIGNIFICANT CHANGES AND AMENDMENTS TO THE 58TH EDITION (2017)
The 58th edition of the IATA Dangerous Goods Regulations incorporates all amendments made by the ICAO Dangerous Goods Panel in developing the content of the 2017-2018 edition of the ICAO Technical Instructions as well as changes adopted by the IATA Dangerous Goods Board. The following list is intended to assist the user to identify the main changes introduced in this edition and must not be considered an exhaustive listing. The changes have been prefaced by the section or subsection in which the change occurs.
22.214.171.124—An exception has been added to address dangerous goods fitted on aircraft equipped for search and rescue to allow the dangerous goods to remain on the aircraft for other flights such as training and positioning flights.
126.96.36.199—A new paragraph has been added to clarify that dangerous goods accepted under the provisions of regulations in force at the time of acceptance by the initial operator can continue to destination even if the regulations applicable to the dangerous goods have changed while the dangerous goods are still in transport, e.g. dangerous goods accepted at the end of December can continue in transport in January even if new provisions affecting these dangerous goods have become effective as of 1 January.
The requirements related to the provision of information to passengers as set out in 1.4.3 have been completely revised to allow for operators to develop performance-based notification system to advised passengers that reflect the operator’s own capabilities and operation. The details of this notification system must be documented in the operator’s operations, or other applicable manual.
1.5.1—“Training Programmes” has been renamed “Dangerous Goods Training Programmes” and a new 188.8.131.52—Review and Approval has been added. The new paragraph replaces the existing 1.5.5—Approval.
A new paragraph has been added that sets out what should be established by shippers of Section II lithium batteries to meet the conditions for “adequate instruction” of employees who are responsible for the preparation of packages of lithium batteries offered for air transport in accordance with Section II of the lithium battery packing instructions.
2.6—Dangerous Goods in Excepted Quantities
2.6.5—The packing provisions have been revised to allow for the absorbent material to be either in the intermediate packaging, or the outer packaging for liquid dangerous goods.
2.8—State and Operator Variations
There are a number of additions, deletions and amendments to variations submitted by operators.
184.108.40.206—A new paragraph has been added to set out the provisions for where a shipper identifies, by testing, that a listed substance has a subsidiary hazard not identified in the list of dangerous goods. The new provision identifies that the shipper must with the approval of the appropriate national authority either use a “n.o.s.” entry or ship the substance under the listed entry with the addition of the subsidiary hazard.
3.1.8—Recommendations have been added that the competent authority responsible for the classification of explosives should provide in writing the details of the classification as detailed.
3.2.6, 3.3.6, 220.127.116.11 and 3.8.4—New provisions have been added to address substances in Class 2, Class 3, Division 6.1 and Class 8, respectively, that may polymerize during normal conditions of transport.
18.104.22.168—Provisions have been added for the classification of polymerizing substances. The provisions are analogous to those for self-reactive substances.
22.214.171.124—The classification requirements for infected live animals have been revised.
4.2—List of Dangerous Goods
Amendments to the List of Dangerous Goods include:
- revision to a number of the entries for aerosols to consolidate all aerosols into packing instructions 203 and Y203;
- addition of special provision A209 against entries with “stabilized” in the proper shipping name;
- all entries of “engines” have been deleted from UN 3166. UN 3166 in Class 9 now only applies to the proper shipping names “vehicles”. Engines are now assigned to UN 3528—UN 3530 in Division 2.1, Class 3 or Class 9, based on the classification of the fuel that powers the engine. Also assigned to UN 3528—UN 3530 are proper shipping names for “machines” which are also based on the classification of the fuel used to power the machines;
- UN 3480, Lithium ion batteries has been amended to show “forbidden” across columns I/J to identify that these batteries are now restricted to Cargo Aircraft Only. This change became effective 1 April 2016 through an addendum to the 57th edition of the DGR. There is no change to the entries for UN 3481, lithium ion batteries packed with equipment or lithium ion batteries contained in equipment;
- all entries for lithium batteries, UN 3090, UN 3091, UN 3480 and UN 3481 have been revised to identify that the hazard label has changed to now be the lithium battery Class 9 label. A new Special Provision A206 has also been assigned to reinforce this new requirement;
- UN 3269, Polyester resin kit has been revised to add “liquid base material” as light type and a new entry “UN 3527, Polyester resin kit, solid base material” in Division 4.1 has been added to provide for polyester resin kits that have a Division 4.1 solid material as the base component;
- four new entries, UN 3531—UN 3534 have been added for polymerizing substances;
- the entries UN 2977, Radioactive material, uranium hexafluoride fissile and UN 2978, Radioactive material, uranium hexafluoride, non-fissile or fissile excepted have now been assigned a subsidiary risk of Division 6.1 in addition to Class 8;
- UN 3507, Uranium hexafluoride, radioactive material, excepted package, less than 0.1 kg per package, non-fissile or fissile-excepted has been revised to now be assigned to Division 6.1 with subsidiary risks of Class 7 and Class 8. The packing instruction assigned is now PI 603.
A21 and A134—Have been revised to address the changes to UN 3166 and the new entries for engines and machinery.
A38—Has been revised to remove reference to polymeric beads.
A66—Has been revised to include reference to the polyester resin kits in Division 4.1.
A88—Which applies to prototype or small production run lithium cells and batteries has beenrevised to now refer to PI 910 in the Supplement to the ICAO Technical Instructions.
A104—Which was assigned to UN 1230, Methanol, and which allowed packages containing methanol to not bear a Toxic hazard label, been deleted. All packages containing methanol must now bear a Division 6.1 hazard label in addition to the Class 3 label.
A112—Has been revised to identify that ID 8000, Consumer commodity can now also include aviation regulated substances, UN 3334 and UN 3335.
A181—Has been revised to more clearly describe the requirements for packages that contain both lithium batteries packed with equipment and lithium batteries contained in equipment.
A202—Is a new special provision assigned to a number of entries for Division 2.2 gases to set out provisions for radiation detectors containing these Division 2.2 gases.
A204—Is a new special provision assigned to Polymeric beads that identifies under what circumstances polymeric beads can be considered to be non-dangerous goods.
A211—Is a new special provision assigned against the entries UN 1067, Nitrogen dioxide and UN 1660, Nitric oxide, compressed to provide for sterilisation devices that incorporate these substances. When in such sterilisation devices these substances may be shipped on passenger or cargo aircraft.
A212—Is a new special provision assigned against the entry UN 2031, Nitric acid, other than red fuming, with more than 20% and less than 65% nitric acid to provide for sterilisation devices that incorporate this substance. When in such sterilisation devices this substance may be shipped on passenger aircraft.
A302 and A324—Have been revised to remove the requirement for the appropriate national authority of the State of destination to also approve the carriage of fish bins with oxygen or ceremonial flames.
A331—Is a new special provision assigned against UN 3480, Lithium ion batteries to identify the possible requirements for a shipper to be able to demonstrate to obtain an approval to ship lithium ion batteries at a state of charge in excess of 30% of the rated capacity of the battery.
126.96.36.199—Dangerous goods in unit load devices and freight containers. The provisions have been revised to allow for unit load devices (ULD) that contain UN 3373 or ID 8000 to also contain dry ice as a refrigerant.
188.8.131.52—New provisions have been added to allow, with the approval of the authorities of the States of origin and of the operator, for the use of UN specification large packagings for articles that weigh in excess of 400 kg.
PI 200—Has been revised to include new provisions for liquefied gases charged with a compressed gas to require the shipper to take both components into account when calculating the internal pressure in the cylinder. There are also additional provisions to require that shippers when charging cylinders must use qualified staff.
PI 203 and PI Y203—These packing instructions have been revised to incorporate the provisions in PI 204, PI Y204 and PI 212. These packing instructions have now been deleted.
PI 218—Applicable to chemicals under pressure has been revised to include new provisions for liquids charged with a compressed gas to require the shipper to take both components into account when calculating the internal pressure in the cylinder.
PI 220—Is a new packing instruction added for engines and machinery powered by a flammable gas.
PI 378—Is a new packing instruction added for engines and machinery powered by a flammable liquid.
PI 450 and PI Y450—Are new packing instructions added for polyester resin kits that have a solid base material classified in Division 4.1. These packing instructions mirror PI 370 and PI Y370, which apply to polyester resin kits with a flammable liquid base.
PI 459—Has been revised to include polymerizing substances (UN 3531 and UN 3532) with self-reactive substances.
PI 603—Is a new packing instruction for UN 3507, Uranium hexafluoride, radioactive material, excepted package, which is now classified with a primary hazard of Division 6.1. Consequently PI 877 has been deleted.
PI 950 and PI 951—These packing instructions have been revised to remove provisions for engines.
PI 954—Has been revised to include allowance for UN 3373, Biological substance, Category B and ID 8000, Consumer commodity to be in a shipper loaded unit load device with the dry ice.
PI 965 – PI 970—Section IB of PI 965 and PI 968 and Section II of all of the lithium battery packing instructions have been revised to remove reference to the need for an additional document to accompany consignments of Section II lithium batteries. As of 1 January 2017 this document is no longer required. The lithium battery handling label, which is required on packages, has been replaced by a new lithium battery mark. The dimensions and colour of the new lithium battery mark are the same as for the lithium battery handling label, but all words have been removed and the UN number(s) is required to be applied. There is a 2-year transition period until 31 December 2018 to allow shippers to implement the lithium battery mark.
PI 972—Is a new packing instruction added for engines and machinery powered by a fuel classified only as environmentally hazardous.
6—Packaging Specifications and Performance Tests
6.4.2—This subsection has been revised to bring in reference to new ISO standards and also to identify the period during which the ISO standards may be applied for manufacture and also after which time the standards may no longer be used.
7—Marking & Labelling
There are numerous editorial amendments to change the word “marking” or “markings” to read “mark” or “marks”. This reflects the correct English usage where what is applied to a package is a “mark”, whereas “marking” is the act of applying the mark.
184.108.40.206—Are the new provisions that set out the requirements for the lithium battery mark. The specification of the lithium battery mark is shown as Figure 7.1.C. The new mark comes into effect as of 1 January 2017 with a 2-year transition period during which time either the lithium battery mark or the lithium battery handling label may be applied to packages containing lithium batteries prepared in accordance with Section IB or Section II of the lithium battery packing instructions.
220.127.116.11—The provisions on additional text on hazard labels have been revised to identify that for the new Class 9 – Lithium Battery hazard label the only information permitted in the bottom half of the label is the pictogram and the class number.
7.3.18—The specification of the new Class 9 – Lithium Battery hazard label has been added as a new Figure 7.3.X. The new hazard label comes into effect as of 1 January 2017 with a 2-year transitional period during which time either the existing Class 9 – Miscellaneous Dangerous Goods hazard label or the new Class 9 – Lithium Battery hazard label may be applied to packages containing lithium batteries prepared in accordance with Section I, IA or IB of the lithium battery packing instructions.
18.104.22.168.1—A note has been added to identify that notwithstanding the change to the UN numbers and division / class for “engines”, that shippers may still consign engines as UN 3166 in Class 9 until 31 March 2017.
22.214.171.124.2—Clarification has been added on how the identification number for multiple overpacks should be shown.
126.96.36.199.4, Step 9—The list of special provision numbers that are required to be shown in the “authorisations” area of the Shipper’s Declaration has been revised.
188.8.131.52.7—The paragraph identifying that for shipments of lithium batteries prepared under Section IB of PI 965 and PI 968 that the information required on the additional document may be included on the Shipper’s Declaration or may be on an additional document has been deleted as the additional document is no longer required.
184.108.40.206 and 220.127.116.11—Have each been revised to remove the mandatory requirement for title of the signatory and the place that the Shipper’s Declaration was signed. This information may still be provided, but is no longer mandatory.
Notes have been added under 9.0 to reference Annex 19 – Safety Management Systems and the ICAO Safety Management Manual. All operators are required to implement a Safety Management System (SMS) and the carriage of dangerous goods is included within the scope of the operator’s SMS.
18.104.22.168—A new paragraph has been added to require that the operator must be able to identify the person who performed the acceptance check.
22.214.171.124—The provisions for acceptance of a shipper loaded unit load device (ULD) containing dry ice have been revised to also allow UN 3373 or ID 8000 to be in the ULD with dry ice.
9.1.9—A new paragraph has been added recommending that operators conduct a safety risk assessment for the transport of dangerous goods.
126.96.36.199.3—The information required on the written information to the pilot-in-command (NOTOC) has been revised to clarify that for ID 8000 the gross weight of each package may be the average gross weight when this is what has been declared on the Shipper’s Declaration.
9.6.2—The reporting of dangerous goods in passenger baggage by operator has been revised to limit the submission of reports by the operator to those where the dangerous goods have been discovered by the operator, or the operator has been advised by the entity that discovered the dangerous goods, e.g. security screeners.
9.8.2—The acceptance checklist retained on file must now include identification of the person who performed the acceptance check.
There are a number of changes and additions to the defined terms in the glossary. These include:
- addition of a definition for “design life” for composite cylinders;
- new definition for “self-accelerating polymerization temperature” to address the new provisionsfor polymerizing substances;
- new definition for “service life” for composite cylinders.
Appendix C—There are revisions to the list of organic peroxides.
Appendix D—Contact details for competent authorities have been updated.
Appendix E—Changes have been made to the list of UN Specification Packaging Suppliers (E.1) and the Package Testing Facilities (E.2).
Appendix F—The list of Sales Agents (F.2), IATA Accredited Training Schools (F.3—F.5) and IATA Authorised Training Centres (F.6) have been revised.
Appendix H—A new appendix has been added for this edition to provide the draft changes to address the implementation of competency-based dangerous goods training. The purpose of this material is to invite comments from all segments of industry: shippers, forwarders, ground handling agents, operators and training providers on potential changes to Subsection 1.5 to implement competency-based dangerous goods training.
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Wholesale Hazardous Goods Boxes
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