Transportation
Lithium Cell/Battery Regulation Information
On April 28, 1999, a shipment of Lithium batteries that was roughly
handled at LAX international airport burst into flames, which resulted in
a federal government investigation. This
investigation determined that these products presented a potentially
serious hazard to all forms of transport but especially to air carriers.
Therefore, as of January 2005, international governments, Canada and US included, require that all battery packs that have been assembled, must be tested in accordance with a set of UN mandated tests. This test consists of 8 procedures that simulate the different environments and situations that exist during transport of Lithium cells or batteries from the manufacturing facility to the customer. Please refer to the links below for information about the tests.
Two options are available to you our customer! First, apply to your local government for a permit that would allow you to transport lithium batteries without the requirement of UN Testing and Certification. Although this option is available, this would only benefit the applicant, when the battery pack is transported by road or rail only within the country that the application has been approved. This permit will not apply to air transportation. The application process will take 2 to 8 months. The second option is to proceed with the UN Testing and Certification which then allows transport of the battery pack in any mode of transport without serious limitations. Even though the customer may have UN Tested and Certified this product, it still may be classified as a Dangerous Goods Product, and require proper documentation, packaging and labelling.
Please note, that although the government exemption would remove the costs of the UN Testing and allows you our customers to continue business as usual, there is a significant drawback. Performing the UN Certification on your products protects you from future fines that could be imposed due to incidents that could happen while your product is in transport. Known as Due Diligence, UN certification confirms that you have taken all measures to ensure your product’s design is compliant and able to withstand the various conditions in transport.
There are two options available for customers who wish to proceed with UN Testing. The first option is to proceed with certification of your product, yourself. While desirable, the costs for single product testing can be prohibitive. As a battery assembly facility, Excell can offer its customers a second option. The regulations allow us to group similar products together, allowing the battery assembly facility to pass some cost savings to you our customer for the certification process where applicable. In both cases the customer would receive a certificate which documents that their product has completed the certification test. Customers should be mindful however that Excell cannot guarantee the outcome of the tests. In some cases the customer may have to redesign their product to meet these new UN mandated safety criteria. This would result in the redesigned product having to be retested.
Excell staff will provide whatever technical assistance is necessary to assist our customers in determining their best course of action in order to comply with the pending new regulations.
Please be advised, that these regulations are being instituted by International government agencies. Non compliance penalties are significant, and impose new levels of responsibility on all parties transporting these products.
Disposal of Lithium Batteries
Lithium Batteries must be disposed of properly. Companies are available to take back your batteries for disposal and process them in accordance with regulations. For recommendations on companies that dispose of your batteries, please contact your local government representatives for information regarding packaging, and transportation regulations.
Government Regulations
The below table will outline where the most important information can be found regarding these regulations.
| United Nations (UN) | US Department of Transportation (DOT) | Canadian Transport of Dangerous Goods (TDG) | International Air Transport Association (IATA) | |
| Dangerous Goods Regulations Location | UN
Manual of Test and Criteria - outline test procedures to
certify a cell or battery pack
UN Model Regulations 13th Edition- search for Special Provisions (188, 230, 310) recommended by UN. Please note that SP 310, has not been accepted by both the US and Canadian Government Regulations
|
Website - US DOT
Lithium Regulations -US DOT Part C, Subsection 173.185
|
Website - Canadian
TDG
Lithium Regulations - Schedule 2, Special Provision 34.1-3 |
Website - IATA
Please note that website does not contain the regulations online, you must purchase these regulations. |
| Training Requirements - anyone packaging, shipping, and receiving DG products must be trained. | N/A | US DOT Part C, Subsection 172.704 | TDG - Chapter 6 | Chapter 1.5, please see above note. |
| Training Agencies | N/A | US DOT - Training Info | Danatec | Kel-Ex |
| Contact Numbers | Office of Hazardous Materials | Canadian National and Regional Offices | Use website contact method. | |
| Government Exemption - Please note that applications for this product may take 2 to 8 months. | N/A | US DOT
Part A, Subsection 107.105
This permit only applies to Ground, and Rail Transport within USA. |
TDG
- Chapter 14
This permit only applies to Ground, and Rail Transport within Canada. |
There are no exemptions available for Air Transport. |
| Additional Information on Regulations Changes | Federal Register - New Regulations on Primary Lithium Batteries |
Cell Manufacturers Documentation Regarding Lithium Regulations
| Panasonic |
Saft |
Ultralife |
Please contact your Excell Battery representative for further information on these topics as required.
Mike
Fekete
Dangerous Goods Transportation Coordinator
Excell Battery Company
Ph:(604) 591-6588
Fax:(604) 591-8779
mfekete@excellbattery.com