Size counts when it comes to transporting lithium batteries
Change is likely in the air when it comes to how the U.S. transports “small” lithium batteries (packed or contained in equipment) by air – cells and packs. The U.S. Department of Transportation (DOT) is currently revamping existing lithium battery air transportation regulations and this has stirred up both concerns as well as approvals as a result. Here is a quick review of how lithium batteries are classified.
|Small (no more than)||Medium (between)||Large (no more than)|
|Cell: Primary||1 g Lithium||1g and 5g Lithium||5 g Lithium|
|Cell: Secondary||1.5 g ELC*||1.5 g and 5 g ELC||5 g ELC|
Battery Pack: Primary
|2 g Lithium||2 g and 25 g Lithium||25 g Lithium|
|Battery Pack: Secondary||8 g ELC||8 g and 25 g ELC||25 g ELC|
*equivalent lithium content Source: U.S. DOT
Under current U.S. DOT regulations, lithium small cell shipments are not required to be classified as “regulated Class 9 hazardous material” - a DOT classification that means the batteries could pose a hazard when transported. Therefore, pallets of small cell lithium batteries could be transported without the air carriers knowledge. Opponents of the current regulation state that even a 5 lb paint can or other flammable Class 9 product must be properly labeled and flight crew made aware of, while a pallet containing thousands of highly volatile lithium cells can be transported without the full scope of the regulation. An argument that is tough to overcome.
However, the argument's flip side states that this proposed U.S. DOT regulation change trumps the international safety requirements for small lithium battery shipments. This creates inconsistencies with global regulations, some of which are even tougher than current U.S. standards. The battery industry is by and large globally orientated. Even cutting-edge lithium battery developers have production and/or distribution agreements with foreign players. Battery supply chains are extremely dependent on transportation to and from various countries.
All in all, while safety is a concern for battery shippers and battery manufacturers, minimal safety incidents (around 40 events) relating to lithium batteries have been reported under the current DOT regulations since 1991 (I find this number hard to believe considering the shear volume level of batteries shipped daily). However, even in the past year, several incidents involving the batteries themselves or battery-powered devices caused significant fire, smoke or evidence of fire has occurred aboard aircraft. Primary lithium batteries have been banned on U.S. passenger aircraft since 2004. Many in the air industry feel similar bans should be upheld for cargo aircraft as well.
A full ban won't come easy or is likely, The first step however - proposed changes to the U.S. DOT regulations relating to shipping lithium battery packs and cells on cargo flights include the following changes (source: U.S. DOT):
- Eliminate regulatory exceptions for small lithium cells and batteries when included in an air shipment; and require their transportation as Class 9 materials, meaning they could pose a hazard when transported;
- Subject packages of small lithium batteries to well-recognized marking and labeling requirements for hazardous materials;
- Require transport documentation to accompany a shipment of small lithium batteries, including notifying the pilot in command of the presence and location of lithium batteries being shipped on the aircraft;
- Require manufacturers to retain results of satisfactory completion of United Nations design-type tests for each lithium cell and battery type;
- Limit stowage of lithium cell and battery shipments aboard aircraft to cargo locations accessible to the crew or locations equipped with an FAA-approved fire suppression system, unless transported in a container approved by the FAA Administrator; and
- Apply appropriate safety measures for the transport of lithium cells or batteries identified as being defective for safety reasons, or those that have been damaged or are otherwise being returned to the manufacturer, and limit the transportation of defective or damaged cells or batteries to highway and rail. Damaged or defective lithium batteries that are being returned to manufacturers would be required to be shipped by highway or rail
Proposed changes are under a 60-day public comment period that initiated on January 11, 2010. DOT officials will then review and include comments in a final ruling, expected fall 2010.