When you were a kid in school did you ever sit in class when the teacher brought up the subject of a report due the next day—knowing that you had no chance of being able to complete it on time—only to have the teacher tell you the deadline was being extended to a later, more manageable date?
This trip down memory lane came to mind because my to-do list for this column has for a while now included reviewing the changes being made in regulations covering safely shipping lithium batteries (ruling HM-224F, set by the U.S. Dept. of Transportation’s Pipeline and Hazardous Materials Safety Administration [PHMSA]). A quick entry in the TTI search engine reveals these products are available from suppliers such as Panasonic Battery, Omron and Phoenix Contact.
Ruling HM-224F affects how lithium batteries will be regulated when shipped by land, sea and air. It’s an important subject since, while everyone acknowledges the fact that lithium batteries offer high performance in a wide range of products, they can pose serious hazards if not packed and handled safely when transported; both metal and ion flavors of lithium are highly flammable and can easily ignite as a result of exposure to a heat source when carried in cargo holds.
Unfortunately for me, mandatory compliance was scheduled to take effect back in February and as the calendar pages turned and other things got in the way I hadn’t tackled the subject here and was resigned to chalk it up as a lost opportunity. And then guess what? Compliance now has been pushed back to August 7, giving businesses a bit more time to conform to the new rules and your humble columnist a renewed chance to talk about what’s involved.
As Yogi Berra once said: “it’s déjà vu all over again.”
Let’s start with a quick review of the energy sources involved. Lithium metal batteries are generally primary (non-rechargeable) batteries that have lithium metal or lithium compounds as an anode. They are generally used to power devices such as watches, calculators, cameras, temperature data loggers, etc. Lithium-ion batteries (sometimes abbreviated Li-ion batteries) are a type of secondary (rechargeable) battery commonly used in consumer electronics. Also included within the category of lithium-ion batteries are lithium polymer batteries. Lithium-ion batteries are generally found in mobile telephones, laptop computers, etc.
Basically, the new rule helps to standardize the way in which lithium batteries and equipment powered by such batteries are shipped. In the past, ground shipments were under one set of requirements while air shipments were held to a more stringent set of standards. Under the new rules, most companies will be able to standardize their shipping process. The rules apply whether lithium batteries are shipped into, out of, or through the United States (including those shipped to or from Canada) and transgressions can result in your company's lithium battery shipments being delayed, returned or even subject to fines.
Rulemaking came about because PHMSA is trying to bring its rules in line with recent changes made to the International Maritime Dangerous Goods (IMDG) Code, the United Nations recommendations on the Transport of Dangerous Goods (known as the UN Model Regulations) and the International Civil Aviation Organization's Technical Instructions (ICAO TI) for safe transport of dangerous goods by air.
As noted air transport has the most stringent rules regarding lithium battery shipment, primarily because Federal Aviation Administration (FAA) tests found that even existing Halon fire suppression systems could not extinguish lithium-initiated fires. So, as of January 1 of this year lithium metal batteries packed by themselves (not contained in or packed with equipment) are forbidden for transport as cargo on passenger aircraft. Note that the rule does not apply to batteries already contained in or packed with equipment, but only to those packaged and shipped separately. Individuals will still be able to bring on board personal devices such as laptops and smartphones, which use lithium-ion batteries.
Now on to the major elements of the PHMSA rules. For openers, there are fewer exception allowances for shipping lithium batteries than in the past. Previously, shippers of “small lithium batteries” were exempt from regulations when the batteries were shipped by ground. Previously, too, packages containing fewer than 24 cells or fewer than 12 batteries were not required to have a hazard mark or special documentation. These will now have to be marked and labelled battery packages when being shipped by ground in the same way they have been prepared for air shipment. Most lithium batteries are now considered as Class 9 hazardous materials when transported by ground transportation, which makes them more closely aligned with the IATA Dangerous Goods Regulations.
There is good news, too. Previous materials regulations included equivalent lithium content (ELC) as a measure of the energy in a lithium battery. Cells could not not exceed 1.5 g of ELC and batteries could not exceed 8 g. Calculating ELC was a pain in the you-know-what because you had to multiply the cell’s ampere-hours by 0.3, but, wait for it, since most small batteries are marked with milliampere-hours, you had to first divide milliampere-hours by 1,000 before multiplying the result by 0.3. Happily, under the new rule, DOT is removing all references to ELC and replacing it with more typical and easier to obtain Watt-hours (Wh), which will need to be marked on each lithium battery.
The new regulations also make it easier to ship prototypes. Special provisions for low production (not more than 100 lithium cells or batteries) and prototype lithium batteries have been replaced by a new provision that’s more aligned with international standards. This change provides relaxed requirements for the shipment of low production runs and prototypes as well as for batteries being shipped for recycling or disposal.
The U.S. Postal Service also has revised its shipping regulations to take into account the PHMSA rules. USPS will not require markings or documentation for parcels containing button cell lithium batteries installed in equipment (including circuit boards) or no more than four lithium cells or two lithium batteries installed in equipment. The Postal Service will require markings and documentation for lithium batteries installed in equipment in domestic air transportation when the number of cells exceeds four up to the allowable limit for air transportation of eight cells.
The postal service notes that when mailing to international destination mail pieces containing lithium batteries may only be sent installed in the equipment they operate.
For more information on transportation of lithium batteries see the PHMSA page on HM-224F at the following URL: