CTACHMM – GENERAL MEETING – DEC 2014

- DOT REGULATIONS FOR LITHIUM METAL AND LITHIUM-ION BATTERIES- PROPOSED CT BATTERY RECYCLING LAW

INCIDENTS

Lithium-ion batteries considered source of fire

Carry 81,000 Lithium batteries

Laptop showing result of Li-Ion fire

A great FAA & CAA training video of Lithium batteries on a passenger aircraft. http://www.youtube.com/watch?v=h05hn1nfe3M 

AGENDA

• General Definitions• Battery• Chemistry• Lithium Metal• Lithium-Ion

• DOT Definitions• Batteries• Batteries With

Equipment• Batteries In

Equipment

• DOT• Shipping Names• Packaging• Labeling• Training

•Personal Travel•Example•CT Battery Recycling Laws

DEFINITIONS

• Battery – a device containing an electric cell or a series of electric cells storing chemical energy that can be converted into electrical power, usually in the form of direct current.

• Chemistry• Primary – used until “dead” and then discarded

• Alkaline• Zinc Air• Zinc Carbon• Lithium Metal• NiOOH

• Rechargeable – electrochemical reactions are electrically reversible (use & recharge)

• Ni-Cad• NiMH• Lead Acid• Lithium-Ion• Fuel Cell

LITHIUM METAL BATTERIES

What are Lithium Metal Batteries?• Higher power batteries, than alkaline• One time use; throw away batteries, not

rechargeable • Coin cells, cylindrical (camera) batteries• 3V combination

LITHIUM-ION BATTERIES

What are Lithium-ion Batteries?• Thinner/flatter batteries • Rechargeable, multiple use• Cylindrical, pack or pouch batteries

• Pouch batteries• MP3• Phones/pads• Non-removable battery

SHIPPING MODES

Ground – DOT US DOT 49 CFR covers all modes of transport within

the US Most carriers accept IATA for air within US Air – IATA International Air Transport Association (pilots &

carriers) New regulations for personal travel ICAO – International Civil Aviation Organization (NGO

body under the UN that coordinates HazMat shipping by Air)

Boat – IMDG International Maritime Dangerous Goods

DEFINITIONS

All Modes of Shipping have these 3 Shipping Names for both Lithium Metal & Lithium-Ion Batteries:

UN3090UN3480

Batteries – By themselves, nothing else in the container

Batteries with Equipment – Batteries & devices separate in the same container

Batteries in Equipment - Batteries IN the device

DOT – 172.101 TABLE UN/Proper ship names consistent with international standards

LITHIUM METAL CELLS & BATTERIES - CHANGES

• Clarification that lithium cells & batteries are subject to UN tests. (38.3)

• A requirement that lithium cell & battery manufacturers create a record of satisfactory completion of the UN testing prior to offering the cell or battery for transport. Maintained for as long as the battery design is shipped & 1 year after.

UN38.3 for A123

LITHIUM-ION BATTERIES - CHANGES

• No more Equivalent lithium content conversion.• Special Provisions 188 & 189 – deleted• 173.185(c)

SPECIAL PROVISIONS, CON’T

• Special provision not listed in 172.101 table – most are in the packaging requirements – similar to IATA & IMDG

• SP29 – low production lithium cells & batteries• SP134 – vehicles powered by wet batteries• SP188&189 – replaced with 173.185©• SP190 – deleted• SPA51-aircraft batteries transported on passenger

aircraft as cargo• SPA54- applicable to lithium batteries over 35 KG• SPA55-prototype batteries shipped by air• SPA100-Not applicable• SPA101 – changed to be comparable to ICAO Technical

Instructions• SPA103&A104 –Lithium=ion packed with or in

equipment been deleted

SMALL & MEDIUM BATTERY EXCEPTIONS/ SPECIAL PROVISIONS

DURACELL SDS – SHOWS LITHIUM CONTENT PER CELL & PER BATTERY

PACKAGING 49CFR 173.185(C)

• Exceptions for highway, rail & vessel for small cells & batteries (& equipment packed with or containing them) consistent with SP 188 from IMDG Code

• Exceptions for air for small cells & batteries (& equipment packed with or containing them) consistent with Section II of PI 965-970

• Exception for medium cells for highway & rail has no equivalent in the international standards – the US is unique.

• PHMSA generally adapted changes that are consistent with international standards.

• New regulations no longer have the “12 batteries or 24 cells no hazard mark or documentation was required” relief.

PACKAGING CON’T – HIGHWAY/RAIL

• Except small lithium metal cells packed with or contained in equipment in quantities less than 5 Kg

• Medium lithium-ion & lithium metal

• Inner packaging must prevent short circuits of batteries/cells

• Ziplock baggies, taping terminal ends, individually bubble wrap, etc.

• Except when cells or batteries are packed with or contained in equipment, each package must not exceed 30 kg GROSS weight

• Except when cells or batteries are packed with or contained in equipment, each package must be capable of withstanding a 1.2 meter drop test in any orientation without damage – doesn’t need to be UN Spec Packaging

PACKAGING CON’T – HIGHWAY/RAIL

• Except for a packaging containing button cell batteries installed in equipment (including circuit boards), or no more than 4 lithium cells or 2 lithium-ion cells or batteries – outer package must be marked:

• CONTAINS LITHIUM METAL OR LITHIUM-ION BATTERIES/CELLS

• PACKAGE TO BE HANDLED WITH CARE & FLAMMABLE HAZARD EXITS IF THE PACKAGED IS DAMAPED

• SPECIAL PROCEDURES MUST BE FOLLOWED IF THE PACKAGED IS DAMAGED

• PHONE NUMBER

ADDITIONAL REQUIREMENTS IF PACKAGED IS SHIPPED BY AIR

In/with equipment:# that powers the equipment + 2 spares – no more than 5Kg lithium cells/batteries

TRAINING

Each person who prepares a package for air transport in accordance with these

air exceptions must receive “adequate instruction on these conditions and

limitations, commensurate with their responsibilities.” Historically, this

phrasing has been interpreted to mean that full haz mat training is not

required.

PACKAGING EXCEEDS QUANTITY OR WEIGHT

Exceeds quantity or weight – CLASS 9 dangerous goods – fully regulated EXCEPT: No more than 2.5 kg lithium metal cells or

10 kg lithium-ion cells Then not subject to UN performance

packaging requirements When Class 9 , Lithium battery handling

Mark & Cargo Aircraft Only Label OR “PRIMARY LITHIUM BATTERIES –

FORBBINE FOR TRANSPORT ABOARD PASSENDGER AIRCRAFT”

Dangerous Goods Declaration filled out Because these are Class 9 regulated shipments,

employees must be trained in accordance with the U.S. HMR.

LITHIUM CELLS/BATTERIES SHIPPED FOR RECYCLING 173.185(D)

Relief applies to all cells & batteries and equipment containing them when they are transjported by highway.

Exceptions from UN testing, recordkeeping and UN performance packaging requirements.

Small & Medium cells/batteries that meet the size, packaging & hazard communication conditions are authorized as excepted shipments when transported by highway.

PRBA – seeking clarification if an “inner packaging” is required.

DAMAGED, DEFECTIVE, OR RECALLED BATTERIES

This provision authorizes the transport by highway, rail, or vessel “lithium cells or batteries that have been damaged or identified by the manufacturer as being

defective for safety reasons, that have the potential of producing a dangerous evolution of

heat, fire, or short circuit (e.g. those being returned to the manufacturer for safety reasons)”

provided they are packaged in or accordance with the provisions listed below. 1. Each cell or battery must be placed in individual, non-metallic inner packaging that completely encloses the cell or battery; 2. The inner packaging must be surrounded by cushioning material that is

noncombustible, non-conductive, and absorbent; and 3. Each inner packaging must be individually placed in one of the following

Packing Group I packages: (i) Metal (4A, 4B, 4N), wooden (4C1, 4C2, 4D, 4F), or solid plastic (4H2) box; (ii) Metal (1A2, 1B2, 1N2), plywood (1D), or plastic (1H2) drum; and 4. The outer package must be marked “Damaged/defective lithium ion battery” and/or “Damaged/defective lithium metal battery,” as appropriate.

DISPOSAL OPTIONS:

CALL2RECYCLE – - Rechargeable batteries

only - Paid for by battery

manufactures - www.call2recycle.org - Home Depot, Radio Shack,

Staples, etc.

THE BIG GREEN BOX – - All chemistries - Paid when boxes are

purchased - www.bigreenbox.com - 877-461-2345

PASSENGER PACKING FOR A PERSONAL TRIP

Lithium & Lithium-ion batteries (spares) & small equipment (cameras)

Are to be brought onto the passenger aircraft as CARRY-ON and not packed in CARGO.

EXERCISE – NEED TO SHIP BACK TO HP 5 LAPTOP COMPUTERS RECEIVED WRONG MODEL – NOT DEFECTIVE

Lithium Ion Battery14.4 Volts2450 mAh

Computer – 5 lbs each

LABEL/ MARK THE PACKAGE:

To: HP ReturnsFrom: Duracell

Shipping Name:UN3481, Lithium-ion batteries contained in equipment, 9, PGII

Doesn’t need to be spec packaging

Can it go by air?

YES

CT CONSUMER BATTERY STEWARDSHIP ACT HIGHLIGHTS

• 1st State in the nation to adopt a comprehensive battery recycling bill

• Both singe-use and rechargeable batteries• Alkaline, zinc carbon, lithium, silver oxide, zinc air,

rechargeable• NOT car batteries

• Retailers – drop off box or curbside recycling bin – being worked out

• Companies selling batteries must come up with a plan

• Behind the law:• Duracell, Energizer, Panasonic & Rechargeable

Battery Association

CT CONSUMER BATTERY STEWARDSHIP ACT HIGHLIGHTS

• Primary or small rechargable battery• Manufacturers – labeled clearly identify the type &

chemistry of the battery• Stewardship Plan

• 10% collection rate 2 years of program is implemented• 20% collection rate 5 years after program is

implemented• Free of charge to consumers

• Both retail & bulk collection sites• Retail – no more than 100 batteries per visit

• Cost by manufacturers based on pounds• Annual report – collection/sales/financial statement

financing of the plan, collection points, educational materials, manner of sorting/recycling

QUESTIONS?