Lithium Batteries Transport and Packaging Instructions Multimodal approach 2024 MARCO OTTAVIANI
Copyright © 2024 This instruction manual has been prepared by Dr. M. Ottaviani. Publishing and delivery in partnership with Hyper srl Bessarione 5b – 30173 Venice (Italy) tel.: +39 041976896 e-mail: info@hyperedizioni.com http://www.hyperedizioni.com Finished to print on June 2024 All rights reserved ©. No parts of this publication can be reproduced without the express editor’s authorization. Even though the editor and the author have paid maximum attention to ensure accuracy, they do not accept any responsibility in the case of errors or omissions. “Illustrations have been prepared in collaboration with AUTEC s.r.l and S.E.VAL. s.r.l. “
5 Table of Content Introduction 9 1. International Transport Regulations 11 1.1 How to use this instruction manual 13 1.2 Definitions 17 1.3 General requirements 19 1.3.1 Test requirements 19 1.3.1.1 Manual of Test and Criteria 19 1.3.1.2 Transitional period 19 1.3.1.3 Exemptions from the testing requirements 20 1.3.2 Manufacturing Quality Control Program 20 1.3.3 Protection from short circuit: 21 1.3.4 Damaged and Defective Batteries 21 1.3.5 Packages with both lithium batteries "packed with" and "contained in" equipment 22 1.3.6 Lithium batteries containing both a combination of primary lithium metal cells and rechargeable lithium ion cells 23 1.4 Packaging 23 1.4.1 Table with Packaging Codes 25 1.5 Marking and Labelling 26 1.6 Documentation 28 1.7 Special Provisions 32 1.8 Packing instructions 33 1.9 Transport Mode specific requirements 34 1.9.1 ADR - Exemption for quantity carried per transport unit 34 1.9.2 IATA - Lithium metal batteries in checked baggage and carry-on baggage 34 1.9.3 IATA - Restrictions on packing lithium batteries with other dangerous goods 36 1.9.3 IATA - Packages in overpack 36 1.10 Training requirements 37 1.11 Lithium batteries in vehicles 39 1.12 Lithium batteries Installed in Cargo Transport Unit 41 1.13 Lithium batteries contained in data loggers and cargo tracking devices 42 2. Shipping Modes Summary Sheets 43 List of Summary Sheets 44 2.1 LITHIUM METAL CELLS & BATTERIES (NEW) 45 2.1.1. LITHIUM METAL CELLS (including lithium alloy cells) – UN 3090 45 2.1.1_IA Fully regulated cells 46 2.1.1_IB Small cells excepted 48 2.1.2. LITHIUM METAL CELLS CONTAINED IN EQUIPMENT (including lithium alloy cells) - UN 3091 51 2.1.2_I Fully regulated cells 52 2.1.2_II Small cells excepted 54 2.1.3. LITHIUM METAL CELLS PACKED WITH EQUIPMENT (including lithium alloy cells) - UN 3091 57 2.1.3_I Fully regulated cells 58 2.1.3_II Small cells excepted 60 2.1.4. LITHIUM METAL BATTERIES (including lithium alloy batteries) – UN 3090 63 2.1.4_IA Fully regulated batteries 64 2.1.4_IB Small batteries excepted 66 2.1.5. LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT (including lithium alloy batteries) - UN 3091 69 2.1.5_I Fully regulated batteries 70 2.1.5_II Small batteries excepted 72
6 2.1.6 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT (including lithium alloy batteries) - UN 3091 75 2.1.6_I Fully regulated batteries 76 2.1.6_II Small batteries excepted 78 2.2 LITHIUM ION CELLS & BATTERIES (NEW) 81 2.2.1 LITHIUM ION CELLS (including lithium ion polymer cells) - UN 3480 81 2.2.1_IA Fully regulated cells 82 2.2.1_IB Small cells excepted 84 2.2.2 LITHIUM ION CELLS CONTAINED IN EQUIPMENT (including lithium ion polymer cells) - UN 3481 87 2.2.2_I Fully regulated cells 88 2.2.2_II Small cells excepted 90 2.2.3 LITHIUM ION CELLS PACKED WITH EQUIPMENT (including lithium ion polymer cells) - UN 3481 93 2.2.3_I Fully regulated cells 2.2.3_II Small cells excepted 96 2.2.4 LITHIUM ION BATTERIES (including lithium ion polymer batteries) - UN 3480 99 2.2.4_IA Fully regulated batteries 100 2.2.4_IB Small batteries excepted 102 2.2.5 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT (including lithium (incl. lithium ion polymer cells) - UN 3481 105 2.2.5_I Fully regulated batteries 106 2.2.5_II Small batteries excepted 108 2.2.6 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT (including lithium ion polymer batteries) - UN 3481 111 2.2.6_I Fully regulated batteries 112 2.2.6_II Small batteries excepted 114 2.3 WASTE LITHIUM BATTERIES 117 2.3.1. WASTE LITHIUM METAL CELLS & BATTERIES (including lithium alloy batteries) - UN 3090 117 2.3.1.1 Fully regulated_P903 118 2.3.2. WASTE LITHIUM ION CELLS & BATTERIES (including lithium ion polymer batteries) - UN 3480 121 2.3.2.1 Fully regulated_P903 122 2.3.3 CELLS AND BATTERIES FOR DISPOSAL or RECYCLING 125 2.3.3.1 Fully regulated cells and batteries 126 2.3.3.2 Strong impact resistant out casing, mass of 12 kg or more 128 2.3.3.3 Small excepted cells and batteries 130 2.3.3.4 Mix lithium cells and batteries with other non-lithium (P909 + SP636_ADR only) 132 2.3.4 CELLS AND BATTERIES CONTAINED IN EQUIPMENT FOR DISPOSAL or RECYCLING 135 2.3.4.1 Cells and batteries contained in equipment 136 2.3.4.2 Cells and batteries installed in Exempted Equipment from private households (SP 670 ADR only) 138 2.3.4.3 Cells and batteries contained in Equipment from private households up to the intermediate processing facility (P 909 + SP 670 ADR only) 140 2.4 CELLS & BATTERIES DAMAGED & DEFECTIVE 143 2.4.1 Not Critical - Non liable to dangerously react during transport 144 2.4.2 Critical - Liable to dangerously react during transport 146 2.5 PRE-PRODUCTION PROTOTYPES & PRODUCTION RUNS ≤ 100 CELLS AND BATTERIES 149
7 Foreword When they are offered for transport, lithium batteries are regulated as Dangerous Goods by the United Nations Transport Organisation and other national transport authorities. This regulation is being permanently adapted to take into consideration the evolution of lithium battery technologies. Indeed, lithium metal battery markets have seen significant developments in the last twenty years. More recently, a similar evolution has been observed with the increasing role played by rechargeable Lithium-ion batteries in electrical and electronic equipment. Battery technology innovation and development helps an increasing number of technicians and engineers to design new equipment powered by portable sources of energy such as lithium batteries. The innovation capacity offered by lithium batteries opens the way to an increasing use of advanced rechargeable batteries in our modern society. The necessity for an increasing number of economic actors to respect the UN Dangerous Goods Regulation requires modern communication tools to inform the shippers of batteries about their duties and responsibilities when offering them for transport. The aim of this manual is to offer a simple and visual means to access the UN Regulation via a modern multimedia communication tool. The regulation is presented in a summarized format covering ground, air and maritime transportation modes. In a page opposite the various regulations, the packaging and labelling instructions are illustrated to facilitate the implementation of the transport regulation as well as the packaging and labelling requirements by the shipper of lithium batteries. The objective of the funding Associations is to offer access to the UN Transport Regulation to the largest number of interested parties in order to make them aware of their duties and responsibilities when shipping lithium metal or lithium ion batteries. We thank Dr. Marco Ottaviani for preparing this exhaustive document with the most updated information and Emanuele Fanizzi, the Editor, who has accepted to translate the information into modern multimedia tools accessible to the largest number of users. Brussels, June 2024
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9 Introduction The complexity of the International Dangerous Goods Transport Regulation for Lithium Batteries requires an increasing attention from those who are shipping these batteries. Lithium batteries are classified as “Class 9” Dangerous Goods in accordance with United Nations Recommendations on the Transport of Dangerous Goods Model Regulations The regulations may frequently change anyway depending on the transport model utilized. This Manual is aimed at delivering basic information to those who are not yet familiar with these International Dangerous Goods Transport Regulations. The manual is divided into two parts. Part 1 is summarizing the main regulation requirements for road, sea and air transport. Part 2 contains 40 Summary Sheets where the different transport modes requirements are summarized in one page. On the opposite page, an illustration of the packaging instructions is offered to the reader and presented with illustrative examples to guide the reader. The Manual is organised according to the UN Number of lithium batteries, considering "new" and "waste" batteries, the “quantities” of batteries that are shipped, starting from the largest “fully regulated” and ending with the small “excepted” quantities. In case of “used” batteries they have to be evaluated individually, as well as “damaged or defective” batteries. This manual is only a guide to assist the reader in preparing lithium batteries shipments for transportation by road, sea and air. It doesn’t replace any of the regulations manual that are applicable to the shipment of lithium batteries. If you have any comment on the content of this Manual, we would be pleased to take them into consideration for any further improvement of its content and its practical use.
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11 1. International Transport Regulations UN Model Regulations The Recommendations concerning the transport of all type of dangerous goods have been developed by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods with the aim to ensure the safety of people, property and the environment. They are applicable to all modes of transport and are addressed to governments and international organizations concerned with the regulation of the transport of dangerous goods. They are published in the “Recommendations on the Transport of Dangerous Goods—Model Regulations”. Edition applicable → 23rd revised edition UN Manual of Tests and Criteria UN Manual of Test and Criteria are developed by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods and published as a separate manual in the “Recommendations on the Transport of Dangerous Goods— Manual of Tests and Criteria”. Edition applicable → Revision 8 ADR The Agreement concerning the International Carriage of Dangerous Goods by Road is consistent with the United Nations “Recommendations on the Transport of Dangerous Goods—Model Regulations”. ADR is an Agreement between States and pursuant to European Directive 2008/68/EC is applied at national level in the Member States on the European Union. Edition applicable → ADR 2023 IMDG International Maritime Dangerous Goods (IMDG) Code is prepared by International Maritime Organization - IMO and is consistent with the United Nations “Recommendations on the Transport of Dangerous Goods—Model Regulations”. IMDG Code harmonizes the practices and procedures followed in the carriage of dangerous goods by sea and ensures compliance with the mandatory provisions of the SOLAS Convention (International Convention for the Safety of Life at Sea) and of Annex III of MARPOL (International Convention for the Prevention of Pollution from Ships). Edition applicable → IMDG Code 41-22 IATA ICAO The International Civil Aviation Organization (ICAO) develops the regulations for the safe transport of dangerous goods by air by any aircraft (including both internal and external carriage) on the basis of the Recommendations on the Transport of Dangerous Goods—Model Regulations. The ICAO regulations are codified in Annex 18 to the Convention on International Civil Aviation and in its Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO – TI’s) and are recognized as the sole authentic legal source material in the air transport of dangerous goods. Edition applicable → ICAO Technical Instruction 2023-2024 edition The International Air Transport Association (IATA) publishes the Dangerous Goods Regulations (IATA DGR) based on the requirements of Annex 18 to the Convention on International Civil Aviation and the associated Technical Instructions for the Safe Transport of Dangerous Goods by Air, published by ICAO. IATA DGR constitute a manual of industry carrier regulations to be followed by all IATA Member airlines. There are certain differences between the IATA and ICAO regulations which stem from operational considerations and result in a regulatory regime which is necessarily more restrictive than the ICAO requirements. The IATA Regulations also incorporate additional material of practical assistance to users. Edition applicable → IATA Dangerous Goods Regulations 2024 – 65th Edition International Transport Regulations
12 Periods of applications of International Transport Regulations This edition refers to the year 2024 International Transport Regulations
13 1.1 How to use this instruction manual This manual is designed to provide a quick and effective guide to personnel who needs to prepare a shipment of lithium cells and batteries, either new or waste, by road, maritime and air transport modes. It consists of two parts. The first part describes and summarizes the regulatory aspects applicable to the transport of lithium batteries, introducing the basic concepts of the transport of dangerous goods, the duties they impose on producers, distributors and users; it also provides a guide to using the manual in order to give to the user the necessary information. In the second part Summary Sheets are provided for the three modes of transport. This information is condensed into one page. On the opposite page, images and flow charts illustrating how to perform in practice the packaging requirements , guiding the user step by step to prepare the correct shipment, in accordance with the regulation. The battery manufacturers have specific compliance obligations during production and only batteries successfully tested in accordance with the UN Manual of Tests and Criteria can be transported and placed on the market. The United Nations Manual of Tests and Criteria, updated periodically, imposes several requirements to be observed by shippers of Lithium Metal and Lithium Ion Batteries. Producers, distributors, users, waste managers, recyclers, all those who ship lithium batteries new or waste or even damaged and defective, or that forward them, with or without re-packing, have the obligation to comply with the applicable regulations depending on the different modes: road, maritime and air. It is therefore necessary to know, for each shipment, how to prepare the batteries, which packaging is allowed, how to mark and label packages and which documents to prepare to accompany the shipment. In additions shippers must take into account specific requirements of each transport mode. The provisions applicable in the various transport modes may differ because they are adapted to ensure maximum safety during transport. This means that regulators have introduced special provisions, restrictions and limitations, or other exemptions and exclusions, with the result of making even more complex the regulatory framework for the transport of Lithium Batteries. This manual will propose a decision path that, in six steps, allows users to access the information needed to prepare lithium batteries for transport with the appropriate packaging shipping papers, markings, and labels. These six steps are schematically presented, for new batteries, in the next flowchart. • Cell or battery Cell : a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Battery: two or more cells which are electrically connected together. Step 1 Lithium Metal or Lithium Ion There are many types of lithium batteries which differ by the nature and composition of the electrodes materials, the substances present in the electrolyte and the capacity to convert chemical energy into electricity. For the purposes of dangerous goods transport regulations, however, lithium batteries classification has been reduced to two groups: lithium metal and lithium ion. Lithium metal batteries, also including lithium metal alloys, consists of cells and batteries containing lithium in the metallic form. They are used to power small consumer electrical International Transport Regulations
International Transport Regulations 14 appliances and devices such as watches, cameras, calculators etc. They can also be assembled into large batteries e.g. in the oil rig drilling heads. Lithium ion batteries including lithium ion polymer battery consists of cells and batteries containing lithium in the ionic form. They are used in consumer electronics, such as mobile phones, laptops, tablets and MP3 players. In the larger sizes they are being used to power cordless power tools, e-bikes, electric or hybrid electric vehicles, energy storage and many other industrial applications. The two groups of Lithium Batteries, the Lithium-Metal and the Lithium-Ion show different hazards and therefore are assigned to two different entries in the UN Dangerous Goods Regulations. The Regulations take also into consideration the transport and packaging requirements of such batteries installed in equipment or packed with equipment: UN 3090 LITHIUM METAL BATTERIES UN 3091 LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT UN 3480 LITHIUM ION BATTERIES UN 3481 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT Step 2 Evaluate and confirm
International Transport Regulations 15 – The content in grams of lithium in the lithium metal cells and batteries – The Wh rating of lithium ion cells and batteries Step 3 Decide if you ship: – Cells or batteries as batteries, – Cells and batteries contained in equipment or – Cells and batteries packed with equipment Step 4 Go to chapter § 2 of this manual and following the chart with the characteristics of your batteries, identify your transport requirements in accordance with the 18 groups listed under Step 4 in the Table. Step 5 Go to the first sheet of the identified group and according to the Flow Chart with the data collected, identify the specific Summary Sheet related to your transportation requirements for the given types of batteries to be shipped. Step 6 LEFT page of Summary Sheet: Use the information of the Summary Sheet from top to bottom, the relevant provisions have been included in the Summary Sheet according to a logical and practical path. The differences in road, maritime and air transport and packaging requirements have been identified by different background colors and highlighted step by step. A white background is used where the provisions are applicable to more than one transport mode. The orange background applies to road transportation, pink applies to maritime transportation and blue applies to air transportation. On the LEFT page, the Summary Sheet contains the following information: Where applicable, a) UN Number, b) Proper shipping Name, c) Class d) Packing Group e) Hazard label f) Prerequisite, conformity to the general requirements g) Specific requirements h) Exemption conditions i) Packing instructions j) Authorized packagings k) Quantity and weight limits l) Provisions applicable to road transportation (i.e. tunnel code, transport category, road transport exemptions) m) Marking and labelling on packages n) Overpack labels and markings o) Specific transport document required p) Instructions to personnel RIGHT page of Summary Sheet: On the opposite page (to the right), images show an example of how to practically prepare packaging for shipment: how to protect cells and batteries from short-circuit, verify and use internal and external packaging, labelling and marking of packages. Example of Six steps method:
International Transport Regulations 16 Lithium metal cell, with Li content 4.5 g/cell, packed as batteries, transported by road Step Actions and data Key words 1 New product (not waste) From the Product Data Sheet: Lithium Metal - New - Lithium Metal - Cell 2 From the Product Data Sheet: Lithium metal content 4.5 g/cell - 4.5 g/cell 3 Packed as batteries - As Batteries 4 Go to § 2 “List of Summary Sheets” and follow the key words: New → Lithium metal → Cells → As Batteries Obtain → § 2.1.1 LITHIUM METAL CELLS - § 2.1.1 5 Go to § 2.1.1 and follow the flow chart for “road transportation” → according the lithium content 4.5 g/cell, your Summary Sheet is → 2.1.1_IA - § 2.1.1_IA 6 → Now apply it following the provision for ADR (the orange column) and the one in white background, which are common to other transport modes End of the search,
17 1.2 Definitions “ADR” means the Agreement concerning the International Carriage of Dangerous Goods by Road. “Approved packagings” means packagings manufactured under a quality assurance programme, which satisfies the competent authority, conform to the prototype which has passed specific tests. “Automotive battery” means any battery used for automotive starter, lighting or ignition power; “Industrial battery” means any battery designed for industrial or professional uses or used in any type of electric vehicle “Battery” means two or more cells which are electrically connected together and fitted with devices necessary for use, for example, case, terminals, marking and protective devices. A single cell lithium battery is considered a "cell”. "Battery pack" means any set of primary or rechargeable cells or batteries that are connected together and/or encapsulated within an outer casing so as to form a complete unit that the end-user is not intended to split up or open. Note: “battery packs”, “modules” or “battery assemblies” having the primary function of providing a source of power to another piece of equipment, for the purposes of this manual are treated as batteries. "Button cell" means any small round portable battery or accumulator whose diameter is greater than its height. “Cell” means a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Note: Under the International Dangerous Goods Regulations and the UN Manual of Tests and Criteria, to the extent the encased electrochemical unit meets the definition of “cell”, it is a “cell”, not a “battery”, regardless of whether the unit is termed a “battery” or a “single cell battery” outside of regulations and the UN Manual of Tests and Criteria . "Consignee" means any person, organization or government which is entitled to take delivery of a consignment "Consignor" means any person, organization or government which prepares a consignment for transport; “IATA DGR” means the International Air Transport Association - Dangerous Goods Regulation "IMDG Code" means the International Maritime Dangerous Goods Code, “Large packaging” means a packaging consisting of an outer packaging which contains articles or inner packaging and which a) is designed for mechanical handling b) exceeds 400 kg net mass or 450 litres capacity but has a volume of not more than 3 m3 “Lithium metal batteries” have lithium metal or lithium compounds as an anode. The most common type of lithium cell used in consumer applications are primary cells using metallic lithium as anode and manganese dioxide as cathode, with a salt of lithium dissolved in an organic solvent. “Lithium-ion batteries” (sometimes abbreviated Li-ion batteries) are a type of secondary (rechargeable) battery commonly used in consumer electronics. Also included within lithium-ion batteries are lithium polymer batteries. “Lithium battery”: in this manual the term "lithium battery" covers all cells and batteries containing lithium in any form. "Manual of Tests and Criteria" mean the Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, published by the United Nations. "Overpack" means an enclosure used to contain one or more packages, consolidated into a single unit easier to handle and stow during carriage; "Package" means the complete product of the packing operation, consisting of the packaging and its contents prepared for dispatch. "Shipper” has the same meaning of consignor. International Transport Regulations
International Transport Regulations 18 "Single cell battery" as defined in Part III, sub-section 38.3.2.3 of the UN Manual of Tests and Criteria is considered a “cell” and must be transported according to the requirements for “cells”. “UN Model Regulations" means the UN Recommendations on the Transport of Dangerous Goods Model Regulation published by the United Nations. "Wastes" means substances, solutions, mixtures or articles for which no direct use is envisaged but which are transported for reprocessing, dumping, elimination by incineration or other methods of disposal. Words “shall", "should" and "may": in the International Transport Regulations, the words "shall", "should" and "may" mean that the relevant provisions are "mandatory", "recommendatory" and "optional", respectively.
19 1.3 General requirements 1.3.1 Test requirements 1.3.1.1 Manual of test and Criteria Each cell or battery is of the type proved to meet the requirements of each test of the Manual of Tests and Criteria, Part III, sub-section 38.3. Batteries shall be of a type proved to meet the testing requirements of the Manual of Tests and Criteria, part III, sub-section 38.3, irrespective of whether the cells of which they are composed are of a tested type. Except for button cells installed in equipment (including circuit boards), manufacturers and subsequent distributors of cells or batteries manufactured after 30 June 2003 shall make available the test summary as specified in the Manual of Tests and Criteria, Part III, sub-section 38.3, paragraph 38.3.5. Due to copyright restriction, this manual cannot contain the text of Manual of Tests and Criteria, however, as a user, you can consult it at the following website: https://unece.org/transport/dangerous-goods/rev7-files 1.3.1.2 Transitional measures Depending on the period of production, cells and batteries can be transported according the following time frames: ADR 2023 Lithium cells and batteries manufactured according to a type meeting the requirements of sub-section 38.3 of the Manual of Tests and Criteria, Revision 3, Amendment 1 or any subsequent revision and amendment applicable at the date of the type testing may continue to be carried, unless otherwise provided in ADR. Lithium cells and batteries manufactured before 1 July 2003 meeting the requirements of the Manual of Tests and Criteria, Revision 3, may continue to be carried if all other applicable requirements are fulfilled. IMDG 41-22 IATA 2024 Each cell or battery is of the type proved to meet the requirements of each test of the UN Manual of Tests and Criteria, Part III, subsection 38.3. Cells and batteries manufactured according to a type meeting the requirements of subsection 38.3 of the UN Manual of Tests and Criteria, Revision 3, Amendment 1 or any subsequent revision and amendment applicable at the date of the type testing may continue to be transported, unless otherwise provided in these Regulations. Cell and battery types only meeting the requirements of the UN Manual of Tests and Criteria, Revision 3, are no longer valid. However, cells and batteries manufactured in conformity with such types before 1 July 2003 may continue to be transported if all other applicable requirements are fulfilled. International Transport Regulations
International Transport Regulations 20 1.3.1.3 Exemptions from the testing requirements: Exemptions under the Road and Maritime Transport Modes (special provision 310) The testing requirements in sub-section 38.3 of the Manual of Tests and Criteria do not apply to • Low production runs consisting of not more than 100 cells and batteries. • Pre-production prototypes of lithium cells and batteries when these prototypes are transported for testing. They have to be packed in accordance to Packing Instruction P910 Exemptions under the Air Transport Mode (special provision A88) Small but significant differences exist in air transport: • Low production runs consisting of not more than 100 cells and batteries per year. • Transport aboard Cargo aircraft must be approved by the appropriate authority of the State of origin, even if all requirements of Packing Instruction 910 are met. Due to copyright restriction, this manual cannot contain the text of the exemption from test requirements, however, as a user, you can consult SP 310 at the following website: https://unece.org/transport/standards/transport/dangerous-goods/adr-2023-agreement- concerning-international-carriage 1.3.2 Manufacturing Quality Control Program Cells and batteries shall be manufactured under a quality management programme that includes: • description of the organizational structure; • responsibilities of personnel with regard to design and product quality; • inspection and test instruction; • quality control instruction; • quality assurance instruction, • process operation instructions; • process controls, including relevant activities to prevent and detect internal short circuit failure during manufacture of cells; • quality records, such as inspection reports, test data, calibration data and certificates; • test data shall be kept and made available to the competent authority upon request; • management reviews under quality management programme; • documents control and revision; • a means for control of cells or batteries that are not conforming to the type tested • training programmes and qualification procedures for relevant personnel; and • procedures to ensure that there is no damage to the final product. NOTE: In house quality management progr mmes may be accepted. Third party certification is not required, but the procedures listed above shall be properly recorded and traceable. A copy of the quality management programme shall be made available to the competent authority upon request. Due to copyright restriction, this manual cannot contain the text of the Manufacturing Quality Control Programme however, as a user, you can consult 2.2.9.1.7 ADR at the following website: • https://unece.org/transport/standards/transport/dangerous-goods/adr-2023- agreement-concerning-international-carriage
International Transport Regulations 21 1.3.3 Protection from short circuit Cells and batteries must be protected so as to prevent short circuits. This includes protection against contact with conductive materials within the same packaging that could lead to a short circuit. Examples of protection against short circuits include, but are not limited to: • individual protection of the battery terminals, • inner packaging to prevent contact between cells and batteries, • batteries with recessed terminals designed to protect against short circuits, or • the use of an electrically non-conductive and non-combustible cushioning material to fill empty space between the cells or batteries in the packaging. 1.3.4 Damaged and Defectiv Batteries Damaged lithium batteries mean in particular, but are not limited to: - Cells or batteries identified as being defective for safety reasons; - Cells or batteries that have leaked or vented; - Cells or batteries that cannot be diagnosed prior to carriage; or - Cells or batteries that have sustained physical or mechanical damage. In assessing a cell or battery as damaged or defective, an assessment or evaluation shall be performed based on safety criteria from the cell, battery or product manufacturer or by a technical expert with knowledge of the cell’s or battery’s safety features. An assessment or evaluation may include, but is not limited to, the following criteria: (a) Acute hazard, such as gas, fire, or electrolyte leaking; (b) The use or misuse of the cell or battery; (c) Signs of physical damage, such as deformation to cell or battery casing, or colours on the casing; (d) External and internal short circuit protection, such as voltage or isolation measures; (e) The condition of the cell or battery safety features; or (f) Damage to any internal safety components, such as the battery management system. Transport of damaged and defective batteries is regulated as follow: ADR 2023 IMDG 41-22 Cells and batteries “not critical” (not liable to dangerously react during transport): Permitted according Special Provision 376 and Packing Instructions P908 and LP904 Cells and batteries “critical” (liable to dangerously react during transport): Permitted according Special Provision 376 and Packing Instructions P911 and LP906 IATA 2024: Forbidden for air transport both “critical” and “not critical” cells and batteries. Cells and batteries “not critical”: NOT liable to dangerously react during transport The packing procedures require approved packagings of packing group II performance level. Packages shall be marked “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES” or “DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES”, as applicable. Cells or batteries shall be protected against short circuit.
International Transport Regulations 22 Each damaged or defective cell or battery or equipment containing such cells or batteries shall be individually packed in inner packaging and placed inside an outer packaging. A cell or battery with a net mass of more than 30 kg shall be limited to one cell or battery per outer packaging. Each inner packaging shall be surrounded by sufficient non-combustible and electrically nonconductive thermal insulation material to protect against a dangerous evolution of heat. Non combustibility shall be assessed according to a standard recognized in the country where the packaging is designed or manufactured. Appropriate measures shall be taken to minimize the effects of vibrations and shocks, prevent movement of the cells or batteries within the package that may lead to further damage and a dangerous condition during carriage. Cushioning material that is non-combustible and electrically non-conductive may also be used to meet this requirement. The inner packaging or outer packaging shall be leak-proof to prevent the potential release of electrolyte. For leaking cells or batteries, sufficient inert absorbent material shall be added to the inner or outer packaging to absorb any release of electrolyte. Cells and batteries LIABLE TO DANGEROUSLY REACT during transport Cells and batteries liable to rapidly disassemble, dangerously react, produce a flame or a dangerous evolution of heat or a dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of carriage. They may be transported according Packing Instructions P911 and LP906. The packing procedures require approved packagings of packing group I performance level and shall be capable of meeting the following additional performance requirements: a. The outside surface temperature of the completed package shall not have a temperature of more than 100°C. A momentary spike in temperature up to 200°C is acceptable; b. No flame shall occur outside the package; c. No projectiles shall exit the package; d. The structural integrity of the package shall be maintained; and e. The packagings shall have a gas management system (e.g. filter system, air circulation, containment for gas, gas tight packaging etc.), as appropriate. In ADR, in this case, the cells and batteries are assigned to transport category 0. Packages shall be marked “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES” or “DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES”, as applicable. Cells or batteries shall be protected against short circuit. Alternative packing and/or carriage conditions may be authorized by the competent authority of any ADR Contracting Party. 1.3.5 Packages containing a combination of lithium batteries "packed with" and "contained in" equipment ADR 2023 IMDG 41-22 SP390 - When a package contains a combination of lithium batteries contained in equipment and lithium batteries packed with equipment, the following requirements apply for the purposes of package marking and documentation: (a) the package shall be marked “UN 3091” or “UN 3481”, as appropriate. If a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package shall be marked as
International Transport Regulations 23 required for both battery types. However, button cell batteries installed in equipment (including circuit boards) need not be considered; (b) the transport document shall indicate “UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT” or “UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT”, as appropriate. If a package contains both lithium metal batteries and lithium ion batteries packed with and contained in equipment, then the transport document shall indicate both “UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT” and “UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT”. IATA 2024 A181 - Air transport regulation clarifies the requirements for this combination of lithium batteries packed with equipment and lithium batteries contained in equipment in the same package: - the package must be marked UN 3091 Lithium metal batteries packed with equipment, or UN 3481 Lithium ion batteries packed with equipment as appropriate. - all applicable parts of both packing instructions must be met. - button cell batteries installed in equipment (including circuit boards) need not be considered. - the total weight of lithium batteries contained in any package must not exceed the limits for passenger aircraft or cargo aircraft, as applicable; - the Shipper's Declaration must indicate UN 3091 Lithium metal batteries packed with equipment or UN 3481 Lithium ion batteries packed with equipment, as appropriate. - if a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package must be marked as required for both battery types and the dangerous goods transport document must indicate both UN 3091 Lithium metal batteries packed with equipment and UN 3481 Lithium ion batteries packed with equipment. 1.3.6 Lithium batteries containing both a combination of primary lithium metal cells and rechargeable lithium ion cells According SP 387, lithium batteries containing both primary lithium metal cells and rechargeable lithium ion cells shall be assigned to UN Nos. 3090 or 3091 as appropriate. When such batteries are carried in accordance with special provision 188, the total lithium content of all lithium metal cells contained in the battery shall not exceed 1.5 g and the total capacity of all lithium ion cells contained in the battery shall not exceed 10 Wh. 1.4 Packaging Dangerous goods shall be packed in good quality packagings. Packagings shall be strong enough to withstand the shocks and loadings normally encountered during carriage, including trans-shipment between transport units and between transport units and warehouses. Packagings shall be constructed and closed so as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure No dangerous residue shall adhere to the outside of packagings during carriage. "Overpack" means an enclosure used (by a single consignor in the case of Class 7) to contain one or more packages, consolidated into a single unit easier to handle and stow during carriage; Examples of Overpack:
International Transport Regulations 24 1. A loading tray such as a pallet, on which several packages are placed or stacked and secured by a plastics strip, shrink or stretch wrapping or other appropriate means; or 2. An outer protective packaging such as a box or a crate; "Package" means the complete product of the packing operation, consisting of the packaging and its contents prepared for dispatch. Dangerous goods shall not be packed together in the same outer packaging or in large packagings, with dangerous or other goods if they react dangerously with each other and cause: (a) combustion or evolution of considerable heat; (b) evolution of flammable, asphyxiant, oxidizing or toxic gases; (c) the formation of corrosive substances; or (d) the formation of unstable substances. Before being filled and handed over for carriage, every packaging, including IBCs and large packagings, shall be checked to be free from corrosion, contamination or other defects Any packaging which shows signs of weakening, with reference to the approved prototype shall no longer be used or shall be refurbished so that it can pass the tests required for the prototype. Plastic packagings For plastics drums and jerricans, rigid plastics IBCs and composite IBCs with plastics inner receptacles, unless otherwise approved by the competent authority, the period of use permitted for the carriage of dangerous substances shall be five years from the date of manufacture of the receptacles, except where a shorter period of use is prescribed because of the nature of the substance to be carried. Approved packagings: The packs must have passed specific tests and conform to the prototype tested. Packagings shall be manufactured, reconditioned and tested under a quality assurance programme which satisfies the competent authority. Shall bear markings which are durable, legible and readily visible, constituted by a sequence of symbols, letters and numbers, i.e.: The United Nations packaging symbol Plastic Drum with removable head For packing groups: I, II, III Maximum Gross mass in kilograms Carriage of Solids The State authorizing the allocation of the mark Name of Manufacturer Year of Manufacturing (last two digit)
International Transport Regulations 25 Not approved packagings: Where packagings which need not meet the requirements of 4.1.1.3 (e.g. crates, pallets) are authorized in a packing instruction or the special provisions, they are not subject to the mass or volume limits generally applicable to packagings (400 kg or 450 L) conforming to the requirements of Chapter 6.1, unless otherwise indicated in the relevant packing instruction or special provision. 1.4.1 Table with Packaging Codes Kind Material Category Code Drums A. Steel removable head 1A2 B. Aluminium removable head 1B2 D. Plywood - 1D G. Fibre - 1G H. Plastics removable head 1H2 N. Metal, other than steel or aluminium removable head 1N2 Jerricans A. Steel removable head 3A2 B. Aluminium removable head 3B2 H. Plastics removable head 3H2 Boxes A. Steel - 4A B. Aluminium - 4B C. Natural wood ordinary 4C1 with sift-proof walls 4C2 D. Plywood - 4D F. Reconstituted wood - 4F G. Fibreboard - 4G H. Plastics expanded 4H1 solid 4H2 N. Metal, other than steel or aluminium - 4N Packing groups letter: X for packing groups I, II and III Y for packing groups II and III Z for packing groups III only "Drum" means a flat-ended or convex-ended cylindrical packaging made out of metal, fibreboard, plastics, plywood or other suitable materials. This definition also includes packagings of other shapes, e.g. round, taper-necked packagings or pail-shaped packagings. Wooden barrels and jerricans are not covered by this definition. "Jerrican" means a metal or plastics packaging of rectangular or polygonal cross-section with one or more orifices. "Box" means a packaging with complete rectangular or polygonal faces, made of metal, wood, plywood, reconstituted wood, fibreboard, plastics or other suitable material. Small holes for purposes of ease of handling or opening or to meet classification requirements, are permitted as long as they do not compromise the integrity of the packaging during carriage.
International Transport Regulations 26 1.5 Marking and Labelling Marking The UN number preceded by the letters "UN" shall be clearly and durably marked on each package. Dimension of the mark: – The UN number and the letters "UN" shall be at least 12 mm high – For packages of 30 litres capacity or less or of 30 kg maximum net mass, they shall be at least 6 mm in height and except for packages of 5 litres or 5 kg or less when they shall be of an appropriate size. – For marks in the form of specific wording, the lettering size shall be at least 12 mm high: • OVERPACK • DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES or DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES • LITHIUM BATTERIES FOR RECYCLING or LITHIUM BATTERIES FOR DISPOSAL Unpackaged article: • the marking shall be displayed on the article, on its cradle or on its handling, storage or launching device. Marking shall be readily visible and legible and shall be able to withstand open weather exposure without a substantial reduction in effectiveness; IMDG Code requires test of at least three months' immersion in the sea. Labelling Labels shall be in the form of a square set at an angle of 45° (diamond-shaped) with minimum dimensions of 100 mm by 100 mm, except in the case of packages of such dimensions that they can only bear smaller labels; this exception is not valid for air transport . They shall have a line 5 mm inside the edge and running parallel with it. Labels shall be readily visible and legible and shall be able to withstand open weather exposure without a substantial reduction in effectiveness; IMDG Code requires test of at least three months' immersion in the sea. Marks and labels used in this manual: Hazard Label Class 9A Minimum dimensions 100 x 100 mm
International Transport Regulations 27 Small Excepted Lithium battery mark Applicable until 31.12.2026 Applicable from 1.1.2023 Lithium battery mark A rectangle or a square of minimum dimensions 100 x 100 mm and the minimum width of the hatching shall be 5 mm. The symbol shall be black, the hatching shall be red. If the size of the package so requires, the dimensions may be reduced to not less then 100 x 70 high. The rectangular mark 120 x 110 mm dimension may continue to be used. For IATA DGR, the character of the UN numbers shall be at least 12 mm height Handling Labels Cargo Aircraft Only for IATA DGR Minimum dimensions 120 x 110 mm
International Transport Regulations 28 1.6 Documentation Any carriage of dangerous goods governed shall be accompanied by the documentation prescribed in this chapter . Dangerous goods description is needed in the following sequence: UN n. / Proper shipping name / the label model (class)/ Packing Group (*) (example: UN 3090, LITHIUM METAL BATTERIES, 9) (*) Lithium batteries have not assigned a packing group. Other information needed are: – the number and a description of the packages – the total quantity of each item of dangerous goods – the name and address of the consignor; – the name and address of the consignee(s). Note: Proper Shipping Name is always “batteries” irrespective they are “cells” or “batteries” Specific documents are required by the different transport modes, which are described below, highlighting their own specificities that must be completed by the consignor. On the following pages are then shown examples of transport documents compiled Road Transportation – ADR Additional information required: • Tunnel restriction code Maritime Transportation – IMDG Code Additional information required: • Emergency response information, use in emergency response to accidents and incidents involving dangerous goods in transport. Air Transportation – IATA DGR Additional information required: • Limitation prescribed for passenger and cargo aircraft • Radioactive material
International Transport Regulations 29 Road Transportation – ADR No standard form is required for ADR transport document, this layout is an example. Consignor fills the parts in yellow of the document.
International Transport Regulations 30 Maritime Transportation – IMDG Code The layout of this form is not mandatory, but the information required are mandatory. Consignor fills the parts in yellow of the document. Note: Do not fill the Box n. 8
International Transport Regulations 31 Air Transportation – IATA DGR Consignor fills the parts in yellow of the document; In the bottom-right corner, the title of the person signing the declaration and the place of declaration is now optional and may be left blank.
32 1.7 Special Provisions Lithium Metal Ion Cells and batteries Contained IN equipment or Packed WITH equipment Cells and batteries Contained IN equipment or Packed WITH equipment ADR UN 3090 UN 3091 UN 3480 UN 3481 188 188 188 188 230 230 230 230 310 310 310 310 - - 348 348 - 360 - 360 376 376 376 376 377 377 377 377 387 387 387 387 - 390 - 390 636 - 636 - - 670 - 670 IMDG UN 3090 UN 3091 UN 3480 UN 3481 188 188 188 188 230 230 230 230 310 310 310 310 - - 348 348 - 360 - 360 376 376 376 376 377 377 377 377 384 384 384 384 387 387 387 387 390 390 IATA UN 3090 UN 3091 UN 3480 UN 3481 Cells and batteries Contained IN equipment Packed WITH equipment Cells and batteries Contained IN equipment Packed WITH equipment - A48 - - A48 - A88 A88 A88 A88 A88 A88 A99 A99 A99 A99 A99 A99 A154 A154 A154 A154 A154 A154 A164 A164 A164 A164 A164 A164 - A181 A181 - A181 A181 A183 - - A183 - - - A185 A185 - A185 A185 A201 - - A201 - - - - - - - - A213 A213 A213 A213 A213 A213 - A220 - - A220 - - - - A331 - - A334 - - A334 - - A802 - A802 A802 - A802 Due to copyright restriction, on the ADR, IMDG and IATA regulations, this manual cannot contain the text of the special provisions applicable to the different transport modes, however, as a user, you can consult it at the following website: https://unece.org/transport/standards/transport/dangerous-goods/adr-2023-agreement-concerninginternational-carriage - Chapter 3.3.1 International Transport Regulations
International Transport Regulations 33 1.8 Packing instructions Lithium Metal Ion Cells and batteries Contained IN equipment or Packed WITH equipment Cells and batteries Contained IN equipment or Packed WITH equipment ADR UN 3090 UN 3091 UN 3480 UN 3481 P903 P903 P903 P903 P908 P908 P908 P908 P909 P909 P909 P909 P910 P910 P910 P910 P911 P911 P911 P911 LP903 LP903 LP903 LP903 LP904 LP904 LP904 LP904 LP905 LP905 LP905 LP905 LP906 LP906 LP906 LP906 IMDG UN 3090 UN 3091 UN 3480 UN 3481 P903 P903 P903 P903 P908 P908 P908 P908 P909 P909 P909 P909 P910 P910 P910 P910 P911 P911 P911 P911 LP903 LP903 LP903 LP903 LP904 LP904 LP904 LP904 LP905 LP905 LP905 LP905 LP906 LP906 LP906 LP906 IATA UN 3090 UN 3091 UN 3480 UN 3481 Cells and batteries Contained IN equipment Packed WITH equipment Cells and batteries Contained IN equipment Packed WITH equipment 968 970 969 965 967 966 Due to copyright restriction, on the ADR, IMDG and IATA regulations, this manual cannot contain the text of the packing instructions applicable to the different transport modes, however, as a user, you can consult it at the following website: https://unece.org/transport/standards/transport/dangerous-goods/adr-2023-agreement-concerninginternational-carriage - Chapter 4.1.4
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