Labelmaster Outlines Impact of New Lithium Battery Transport Rules

New Rule Harmonizes Lithium Battery Transport Regulations and Adds Marking/Labeling Requirements for Ground and Air Shipments

New safety provisions for transporting lithium batteries became official in the U.S. on March 6, 2019, adding additional marking and labeling requirements for lithium battery shipments transported by road, rail and air. The long-awaited Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) Interim Final Rule (IFR) generally harmonizes the DOT 49 CFR with the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air regulations, which has been effective in the ICAO TI since April 1, 2016.

Below Labelmaster outlines these changes and what they mean for shippers.

Summary of the Changes

The major changes applicable to the air transport of lithium cells and batteries in the US, effective immediately:

• Prohibits the transport of standalone lithium-ion cells and batteries as cargo on passenger aircraft (does not apply to lithium-ion cells and batteries contained in or packed with equipment).
• Limits standalone lithium-ion cells and batteries to a 30% state of charge (SOC). A limited exception exists for cells/batteries used to power medical devices (requires PHMSA approval).
• Limits excepted shipments of lithium ion and metal cells/batteries to one package per consignment or overpack.

A major marking/labeling requirement is also included in the IFR that impacts road and rail shipments containing excepted lithium ion cells (≤ 20 Wh) and batteries (≤ 100 Wh) shipped in accordance with 49 CFR § 173.185(c). These types of shipments were already required to display the lithium battery mark, but now they must also display either the marking “LITHIUM ION BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT’’ or be labeled with a ‘‘CARGO AIRCRAFT ONLY’’ label. It is important to note that this requirement also applies to lithium-ion cells and batteries contained in/packed with equipment (UN3481) where the package exceeds 5 kg.

According to Brian Beetz, manager of regulatory affairs and corporate responsibility for Labelmaster, “The regulatory requirements for shipping lithium batteries are complex and continue to expand, and having the rules vary by transportation mode only adds to the confusion and increases the chances of mistakes. The new IFR will generally harmonize DOT and ICAO regulations – further promoting safety across the industry by taking steps to ensure standalone lithium-ion batteries are not inadvertently loaded to aircrafts, which can happen with multi-modal transportation.”

Unlike most transport rule changes, there is not a transition period. This makes it critical for companies transporting lithium batteries to understand the changes and ensure their organizations are complaint with the new regulations immediately.

What Shippers Can Do

• Read up on the latest regulations and understand their impact on your operations
• Use “Cargo Aircraft Only” handling labels for lithium battery shipments that meet the criteria
• Implement proper processes to ensure all shipments are safe and compliant – across the supply chain
• Partner with a regulatory expert to answer questions and help ensure compliance

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