[an error occurred while processing this directive]

January 2001 Newsletter
press here for back issues

Happy New Year to all our customers and website visitors.

New U.S. Requirements for Non-Regulated Lithium Batteries:

Lithium batteries have been around for a long time. Originally they were classified as a Flammable Solid (Division 4.1), with a sub-risk of Dangerous When Wet (Division 4.3). Any amount of this material required a label as well as a placard on vehicles within the United States. A U.S.D.O.T. exemption was also required. By air, even under the exemption, the batteries were forbidden on passenger-carrying aircraft. Very strict packaging requirements were required.

As the battery industry developed better manufacturing standards and improved quality control testing procedures certain relaxations in the regulations occurred - they were assigned to Division 4.3, no sub-risk was assigned, and provisions were added allowing very small batteries to be excepted from the regulations under certain circumstances. Very strict packaging requirements and quantity limitations continued to prevail, even for the so-called non-regulated lithium batteries.

As the U.S. D.O.T. worked diligently with its United Nations harmonization efforts lithium batteries were reclassified one more time to Class 9. Non-regulated status remained for the small batteries containing very small quantities of lithium. Perhaps the use of Class 9 has encouraged people to think it is hardly worth their attention.

As time has gone by, the so-called non-regulated (small) batteries increasingly became involved in transportation accidents and incidents. Although mishandling appears to be the prime culprit, it appears that safe packaging techniques seemed to take a back seat to economies in packaging, maybe not so much by the manufacturer, but by the shippers (distributors may be a better description) and forwarders.

By virtue of this prevailing cavalier attitude in handling and repackaging the number of incidents has increased - fires and near fires and a few explosions - causing the National Safety Board and the DOT Research and Special Programs Administration to re-visit their positions regarding the so-called small, non-regulated batteries.

Through voluntary efforts within the lithium battery industry, RSPA, and the US FAA new rules have been implemented governing the non-regulated lithium batteries. A portion of the RSPA announcement follows. Where appropriate, we have used bold print to highlight some important requirements.

(Effective 1 February 2001)
Each shipment of covered products that is originated by a participating company and contains more than 20 new primary lithium cells or 10 new primary lithium batteries will be marked to identify its content and recommended response actions in the event of an accident or damage to packaging. The text will appear in both English and the language of the shipment's origin, and will state ``Lithium batteries inside. Do not damage or mishandle this package. If package is damaged or mishandled, batteries must be quarantined, inspected, and repacked.'' The label will include a toll free number to call in the event of an emergency.

Each shipment of covered products that is originated by a participating company and contains more than 40 new lithium ion or lithium polymer cells or more than 20 new lithium ion or lithium polymer multi-cell battery packs (regardless of the number of cells in each) will carry a label explicitly identifying its content and recommended response actions in the event of an accident or damage to packaging. The text will appear in both English and the language of the shipment's origin, and will state "Lithium ion rechargeable batteries inside. (No lithium metal.) In the event of fire, use Class B or C extinguisher. If package is damaged or mishandled, batteries must be quarantined, inspected, and repacked."

Packages which are marked will not exceed 30 kg and will be UN 4G fiberboard boxes, at the Packing Group II performance level, or equivalent.

Participating companies will provide to air carriers, freight forwarders and other shippers involved in the air transportation of covered products brochures or similar documents that describe the covered products and packages, the physiochemical characteristics of covered products, the communications program, and safe shipment handling procedures for covered packages.

Issued in Washington, DC, on August 30, 2000.
Robert A. McGuire,
Associate Administrator for Hazardous Materials Safety.
[FR Doc. 00-22838 Filed 9-6-00; 8:45 am]

We would like to point out that both regulated and non-regulated batteries are forbidden in transportation if the batteries are packaged in such a manner that they may cause a short circuit or buildup of heat. During WW II there was a famous motto: "Loose Lips Sink Ships". Perhaps in 2001 we should adopt the phrase "Loose batteries cause accidents".

New Subjects:

IATA's Dangerous Goods Regulations for 2001 -
Due to delays at a variety of International Regulatory Agencies IATA has gallantly revamped the 42nd Edition of the DGR. Some entries will go out of existence on June 30th and be replaced with new entries on July 1st. A major overhaul of the Radioactive Regulations goes into effect on July 1st which has forced IATA to print both the current version and the new version of the RAM Requirements. There have been a number of additions and changes in the State and Operator Variations in Section 2.9 and major changes to Special Provision A-45 dealing with Lithium Batteries, which is also the lead topic in this newsletter.

Our own "HOT LINKS" and "SPECIAL INFORMATION FOR AIRLINE EMPLOYEES" in our December Newsletter dealing with the USG Variations will remain in this month's Welcome Page to insure the widest possible exposure to our visitors.

All new format in the IMO Dangerous Goods Code for shipments by water -
A totally new format has been developed by the IMO, doing away with the 5 volume set of regulations. The five books have been replaced by a set of 3 books in a format that closely resembles the ICAO and IATA Regulations. This has resulted in an extensive reduction in the cost of securing the regulations from about $450 to approximately $250. R-A Specialists will include these new regulations in our Ocean Training Programs. The New IMDG Code went into effect voluntarily on 1 January 2001. It becomes mandatory on 1 July 2001.

Our IMDG Training will remain as a three day initial training class but, due to the new format, recurrent training is being expanded to two full days, at least through 2003 and possibly beyond.

For our 2001 training schedules click on "Training" or on the top of this page.

While we are on the subject of training, you ought to click on "Links" on the top of this page and then click on "FAA" for the current list of fines by the U.S. FAA. Note that just about all of the fines involve the failure of the shipper or forwarder or carrier to train their employees.

Paperwork, paperwork, paperwork…..includes "shipping papers", the phrase used by the U.S. D.O.T., and bills of lading, used by truckers, ocean and rail carriers, and dangerous goods declarations, the terminology used by ICAO/IATA/IMO is becoming a major safety issue by enforcement personnel. Dangerous goods must be listed separately from non-dangerous goods on your paperwork. Be careful that your traffic personnel do not take short cuts on the "paperwork" used by your local trucker or the highway carrier used to transport dangerous goods to the ocean or air carrier. Frequently the local trucker is merely given a bill of lading indicating total pieces and total weight but with no description of the dangerous goods.

Dangerous goods must be listed in the following order - exactly - Proper Shipping Name (PSN), class and, if applicable, sub-risk in brackets, UN ID Number, Packing Group Number (in Roman Numerals). The number of pieces for each type of package (steel drums vs fibreboard boxes) and the quantity being shipped (trucks, rail, and water use gross weight) and net weight or volume usually for air shipments must appear before or after the basic description (PSN, etc.) and don't forget the 24 hour emergency response number.....AND...the written emergency plan.

Ebola Virus Update: As of December 29, 426 victims have been identified and 165 deaths have occurred in Uganda.

Mad Cow Disease, the technical name is Bovine Spongiform Encephalopathy or BSE, continues to be a major issue in the European Union. The human version of this disease is Creutzfeldt-Jacob Disease and cases continue to show up in Europe and other parts of the world.

The Third Annual HMAC/PIRA Global Conference will be held on March 29-30, 2001 at the Heidleberg Marriott Hotel in Heidleberg, Germany. Click on "Links" at the top of this page then click on "HMAC" for information about the conference as well as other information about HMAC - the Hazardous Materials Advisory Council. The subject is "Are the Regulations Truly Harmonized?" Representatives of European States and the U.N. will be featured speakers concerning a variety of topics of particular interest to the European Community and others involved in international transportation. We hope that many of our own clients from the U.S. and Europe will be able to attend this important conference. If you do attend, be sure to look us up to say hello.

Next month we will back on track dealing with hazard classifications. Radioactive Material will be the topic. No, we will not attempt to make you in to a nuclear scientist.
But we do want to take some of the mystery out of shipping RAM's and explain the dangers particularly as they may affect your health. New regulations covering radioactive material go into effect on 1 July 2001.

Have a happy and prosperous and error-free New Year.

Check our training schedules for upcoming training dates.
[an error occurred while processing this directive]