Transportation Guidelines
The U.S. Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) Lithium battery final rule was published on August 9th, 2007 in the Federal Register. This long awaited rule will harmonize the U.S. lithium battery hazardous materials regulations (HMR) with those that have been in effect internationally since 2003.
The publication of the final rule incorporates many of the dictates from the Agency's previous proposed rule as well as changes from the 2004 interim final rule on lithium metal (primary) batteries. Substantial regulatory and formatting changes to the lithium metal (and lithium ion) battery provisions in U.S. HMR have been unveiled. The effective date of the rule is January 1, 2008; however, some of the special provisions will go into effect later.
All lithium primary and li-ion battery packs, regardless of their size, will need to be tested according to the United Nations (UN) manual of Tests and Criteria prior to their production shipments. See UN Test Guidelines.
As summarized in the chart below, three categories of batteries are defined in the U.S. DOT's rule based on their "size" or Equivalent Lithium Content (ELC). ELC is calculated in grams on a per cell basis to be 0.3 times the rated capacity in ampere hours. Thus, the equivalent lithium content for a battery/battery pack is the rated capacity in ampere hours for a single cell multiplied by 0.3 and then multiplied by the number of cells in the battery/battery pack.
| Small (no more than) |
Medium (between) |
Large (more than) |
||
| Cells | Primary | 1 g Li | 1 g and 5 g Li | 5 g Li |
| Secondary | 1.5 g ELC* | 1.5 g and 5 g ELC | 5 g ELC | |
| Batteries | Primary | 3 g Li | 2 g and 25 g Li | 25 g Li |
| Secondary | 8 g ELC | 8 g and 25 g ELC | 25 g ELC | |
| * ELC (Equivalent Lithium Content) | ||||
"Small" size lithium battery packs that have passed the UN testing requirements, including batteries packed with or installed in equipment, can be transported "non-restricted." (That is, the batteries do not have to be shipped as fully-regulated Class 9 hazardous materials.) The actual requirement for testing small battery packs does not go into effect and become mandatory until October 1st, 2009. However, most battery pack manufacturers are already prudently testing these battery packs.
"Medium" size lithium battery packs that have passed the UN testing requirements, including batteries packed with or installed in equipment, can be transported non-restricted by motor vehicle or rail only. If these lithium batteries are to be transported by passenger or cargo aircraft they must be shipped as fully-regulated Class 9 hazardous materials.
"Large" size lithium battery packs that have passed the UN testing requirements, including batteries packed with or installed in equipment, must be shipped as fully-regulated Class 9 hazardous materials.
One of the more significant issues addressed in the U.S. DOT's rule is confirmation that single-cell lithium battery packs do not require UN testing provided that the cell was previously tested and passed the UN testing as outlined in the Manual for Tests and Criteria.
The U.S. DOT certainly has not finished their work on lithium batteries. Micro Power Electronics expects the Agency to publish a new proposed lithium battery rule in late 2008 to harmonize its regulations with the changes recently adopted at the international level. For example, starting January 1, 2009 under the international regulations, lithium metal batteries and li-ion batteries will be assigned separate identification numbers (also known as UN numbers). UN3480 will be assigned to lithium ion batteries (including polymers), while the existing number UN3090 will only cover lithium metal (primary) battery packs. In addition, UN3481 will be assigned to li-ion batteries contained in or packed with equipment. While the counterpart number for lithium metal (primary) batteries is UN3091.
The determination of the size of a li-ion battery pack for shipping classification has up to now been done by an unusual calculated measurement of "equivalent lithium" using a formula to come up with ELC. Starting January 1, 2009 for international shipments by air or by sea, the determination is changing to a method of watt hours. Watt hours are defined as the rated capacity multiplied by the nominal voltage. The new exception limits are set at 20 watt hours for cells instead of 1.5 g ELC, and 100 watt hours for battery packs instead of 8 g ELC. The watt hour rating must be placed on the label of excepted battery packs (no more than 100 watt-hours) so it can be seen by users of the product.
Within a couple days of this change, it is expected that the DOT will issue a proposed harmonization ruling which will allow all shippers in the U.S. to use this method as well as long as they are shipping by Air or by Sea only. One important note that should not be overlooked is that after Jan 1st, 2009 shipping lithium batteries by Ground or by Rail in the US will still be required to use the ELC method of determining the size of the battery pack.
Another of the changes on January 1st, 2008 effects most of us that fly with consumer electronic and medical devices is that it will now be specifically prohibited to transport spare battery packs in "checked" baggage. All spare batteries should be transported in carry-on baggage and must conform to the following rules. Each spare battery must be individually protected so as to protect against short circuits. This includes the very popular 9V battery type, as these are very easily shorted while being transported if not protected properly. Each battery installed in a device or carried on as a spare must not exceed 2 grams of lithium if it's a primary (lithium metal) battery, or have an ELC of more than 8 grams if it's a li-ion battery pack. Although up to two battery packs with an ELC of more than 8 grams (but less than 25 grams) may be carried-on as spares.
The U.S. DOT has created a new website (http://safetravel.dot.gov/) as an aid to travelers to answer their questions about how to handle all types of battery packs when traveling by air.
These regulation changes are overwhelming to understand and apply to your specific product or shipping patterns, so if you have any questions please contact Micro Power or visit the PRBA (Portable Rechargeable Battery Association) web site (www.PRBA.org) for further information.
