Here are some questions recently received from an awesome seminar attendee!
Are there DOT Hazardous Material Regulation (HMR) exceptions when shipping lithium cells or batteries?
The Department of Transportation (DOT), provides exceptions for smaller cells and lithium batteries in 49 CFR, paragraph 173.185(c), based on the number of cells or batteries in each outside packaging and the “Wh hours” listed on ion rechargeable and the “amount of lithium” contained in each metal cell or battery. This paragraph can except shippers from hazardous material shipping papers, marks, hazard class labels, emergency response information and UN/DOT specification packaging requirements.
Note: In 173.185(d), when larger cells or batteries are shipped for disposal or recycling, DOT provides relief from UN/DOT specification container requirements, but not the hazard communication requirements in Subpart C through subpart H of part 172.
How do you select DOT approved proper shipping names and containers when offering lithium cells or batteries?
When shipping lithium cells, batteries or any other hazardous material, proper shipping names are found in column 2 and packaging instructions in column number 7 and 8 of the 172.101 Hazardous Materials Table in the HMR. In the case of packaging both columns of the table must be referenced, for example, column number 8 of the HMT, could recommend packaging that column number 7 could restrict and vice versa.
How often does DOT container closure training have to be carried out when shipping lithium cells or batteries ?
All UN/DOT specification containers have closure requirements per manufacturer instructions. Specification hazardous material containers must pass drop, stacking, vibration and leak proof testing. All closure notifications and instructions per 173.22(4)(ii), must be maintained for at least 90 days after a container is closed for shipment. And re-training would be required every three years unless the container or it's instructions changed. (see; Rob’s Blog “Closure Requiremets”)
Are placards required when cells or lithium batteries are being transported?
Paragraph 172.504(f), provides exceptions from placarding, in subparagraph (9), for shippers and carriers from offering or displaying the Class 9 placard. However there is no exception for displaying the UN identification number on packaging or transport units when shipping Class 9 in bulk containers.
Can we ship ion and metal lithium cells and batteries in the same outside packaging?
Rechargeable Ion and non-rechargeable metal cell and lithium battery packaging authorizations are found in 173.185, as specified in column 8 of the 172.101 HMT, and are authorized to be shipped in the same outside packaging in certain cases. As long as the inner packaging requirements and the Special Provisions in column 7 of the HMT, are also met.
Are “RQ” requirements applicable when shipping lithium cells and batteries?
Lithium chromate is the only lithium listed in Appendix A to the172.10 HMT, the List of Hazardous Substances and Reportable Quantities, in which Lithium chromate, lists a “RQ” value of 10 pounds, for each package when shipped. A quick scan of a few OSHA safety data sheets, seems to reveal that lithium chromate is not a major or even a common component in most cells or batteries. However, it is always the shipper’s responsibility to decide if RQ values are met.
“LITHIUM CELLS AND BATTERIES ARE NOT DIFFICULT TO SHIP PER SAY, HOWEVER WHEN DOING SO, KNOWING THE ANSWERS TO THE FOLLOWING QUESTIONS BEFORE YOU REFERENCE SECTION 173.185 WOULD MAKE THE JOB MUCH EASIER”.
Are you shipping batteries or cells?
Can you get a copy of the OSHA Safety Data Sheet?
Are the cells or batteries being shipped “individually” or are they shipped “with” or contained “in” equipment?
What is the Watt hour range on the lithium ion cell or battery?
What is the lithium content in the metal lithium cell or battery?
What is the gross weight of each cell or battery?
Are you shipping lithium cells or batteries for disposal or recycling?
Can you ship your smaller lithium cells or batteries using the 173.185(c) hazard communication and packaging exemptions?
Are you shipping by air, ground or both?
Are they being shipped in overpacks?
If they are being re-shipped can you get a copy of the original hazardous material shipping paper and a photo of any of the inner and outer container with the markings that were used?
I love conducting my seminars, but your questions help me truly understand the regulations, provide me with examples and usually make me look more impressive in my next session. Thank you.
Be safe!
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc
Hazmat.tsp@gmail.com