In the United States, and around the world, new standards are emerging around the handling and shipping of lithium batteries. The United States Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) HM-224F ruling became effective earlier this month in hopes of providing clear instructions on safe handling and transportation of lithium batteries.
Lithium batteries are the power source of choice in many electronics applications that need performance and reliability (from notebook computers and tablets to cameras, medical devices, cell phones, power tools and electric cars). At the same, the batteries can be hazardous to ship and demand special treatment when shipped by land, sea, and air.
In addition to DOT regulations, other emerging standards will impact OEMs shipping products between countries. For example, recent actions by the International Civil Aviation Organization (ICAO) has resulted in additional restrictions including prohibiting lithium metal batteries aboard passenger aircraft as of January 1, 2015.
There is great concern that commercial airplanes don't have the fire fighting equipment to manage problems, Bob Richard, vice president of regulatory and government services at Labelmaster told EBN in an interview. Many airlines are being proactive and conservative. For instance, Qantas, Air France and Emirates will no longer accept lithium metal batteries on cargo aircraft.
“The airlines are being pressured by pilots and are taking more conservative approaches and implementing their own restrictions around lithium batteries and that make a huge impact on supply chain,” Richard said. “I'm worried particularly about healthcare applications and those manufacturers not being able to get their products into the hands of customers.”
Concerns also about when these batteries are shipped by sea. “OEMs don't want to put these batteries in ocean cargo because the products can be exposed to salt water environment and overseas shipping is not quick and reliable,” said Richard.
At the same time, many electronics OEMs already have safeguards in place to keep shipping safe. “Safety is key but regulators have to be aware of implications to supply chain,” said Richard. “While the battery and electronics industries have an outstanding track record of safely shipping lithium ion batteries, there have been incidents mainly the result of less scrupulous shippers involving poorly packages, improperly manufactured and tested batteries and non-compliant shipments.”
HM-224F is designed to align provisions around batteries in the United States with international students, such as International Civil Aviation Organization (ICAO) Technical Instructions, the International Maritime Dangerous Goods (IMDG) Code and the UN Model regulations. The standard reduces the acceptable allowances for shipping lithium batteries and outlines packaging, as well as marking/labeling requirements.
At the same time, if electronics OEMs fail to package shipments containing lithium batteries properly, carriers are likely to reject the shipment and bring the supply chain to a grinding halt. Further, failure to comply can result in delayed and returned shipments, and even fines, Richard said.
It's critical, then, that OEMs change their procedures around packaging and handling lithium batteries and products containing lithium batteries. Now, shippers must track a variety of information including: the types of lithium batteries being shipped, their electric capacity, the number of pieces, and how they are packaged.
Richard offered a list of the changes that the standard makes:
- 12/24 Exception Eliminated – Old provisions stated that if a package contained no more than 12 lithium batteries or 24 lithium cells, no hazard mark or documentation was required. The new regulations do not include this 12 battery/24 cell relief, which means many of shipments will now be regulated as Dangerous Goods. In addition, the new provision distinguishes between modes of transport with regard to the size of the package and type of mark required.
- New, Simplified Proper Shipping Names and UN Numbers – To align with international standards, PHMSA has adopted alternative proper shipping names for lithium ion and lithium metal batteries and new UN numbers.
- Low Production Runs and Prototypes – The new regulations make it easier to ship prototypes. Special provisions for low production lithium cells and batteries and prototype lithium batteries by air were deleted and replaced by a new provision that's more aligned with international standards. This change will alleviate the need to secure approvals from PHMSA for ground and rail shipments of prototype and low production cells and batteries, but manufacturers still need approval for shipments by air.
- Watt-Hours Replace Equivalent Lithium Content – Under the previous regulations in the 49CFR, shippers needed to know the “equivalent lithium content” of the batteries being shipped. The new regulations replace equivalent lithium content with the more standard measure of watt-hours.
- Cells and Batteries Packed With/In Equipment – When packed with equipment, a lithium battery may be placed in inner packaging that meets the Packaging Group II performance requirements. For lithium batteries contained in equipment, the packaging is no longer required to be waterproof.
- Shipping Lithium Cells or Batteries for Disposal/Recycling – The final rule provides relief for cells and batteries that are transported by motor vehicle. In addition, small or medium batteries that would have been classified as fully regulated are now exempt when transported by motor carrier.
- New Paperwork Retention for Manufacturers – Lithium cell and battery manufacturers must create a record of satisfactory completion of the UN testing prior to offering the cell or battery for transport
HM-224F will bring big changes to the way lithium batters are transported in the United States. At the same time, there's hope that, as organizations put systems in place, that these same regulations will streamline shipments domestically and internationally. In the meantime, the industry needs to turn its attention to the issue of compliance. Richard said:
One of my concerns that is shared by the industry and some regulators is the constant tightening of the regulations while those that ship non-compliantly are not held accountable for their actions. Additional restrictions will only impact compliant shipments, it does nothing to stop those shippers who deliberately don't comply with the requirements from continuing to ship non-compliantly and it most likely increases the likelihood of such poor behavior putting the public at greater risk.
Let us know your thoughts on these issues. How do you think lithium battery regulations will help or hinder the electronics supply chain?
— Hailey Lynne McKeefry, Editor in Chief, EBN