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Upcoming Dangerous Goods Training Classes - 2012

(All Feature Lithium Batteries)
  • April 10, 2012 (Tuesday) Air Recurrent
  • May 8, 2012 (Tuesday) Ocean Recurrent
  • May 22-23-24 (Tue-Wed-Thurs) Ocean Initial
  • June 5-6-7 (Tue-Wed-Thurs) Air Initial
  • Domestic Cosmetics and Perfume Shippers On-Line Program available 24/7 (Features Special Permit 9275)

Domestic Cosmetics and Perfume Shippers On-Line Program available 24/7 (Features D.O.T. Special Permit 9275)

In-House Training subject to schedule availability.

Check our website for the 2012 Schedule which is now available.

Lithium Batteries

We had never expected that lithium batteries would become a monthly issue in our newsletters. On a daily basis we see the confusion and countless errors made by shippers and forwarders. While the battery lobby works tirelessly to avoid regulation we also see other parties in the transportation chain ignoring due diligence because they themselves are confused due to the complexity of the regulations. Still, others simply take the position that “it’s not my job”.

Well, our job is going to get tougher in 2013.

ICAO just released its anticipated changes in the lithium battery regulations going into effect on 1 January 2013.

You can view the report here. While we are still studying these changes and will try to give some guidance in future newsletters it appears that ICAO has set up a three tier set of regulations.

The first tier would deal with fully regulated lithium batteries that will require UN Specification packaging.

The second tier will deal with fully regulated lithium batteries that will not require UN Specification packaging.

The third tier would represent non-regulated lithium batteries similar to what is in Section II of all six packing instructions currently in effect. The total watt hours per cell and per battery will still be the criteria to determine whether the cells or batteries are fully regulated, “not so fully regulated” (our terminology) and not regulated.

Just before we were going to send this newsletter off to Tom, our webmaster, IATA issued a summary of the changes. You can view the summary at http://www.iata.org/whatwedo/cargo/dangerous_goods/Pages/lithium-battery-change.aspx  

Here are a couple of examples of the new P/I 965:
This packing instruction is structured as follows:
  • Section IA applies to lithium ion cells with a Watt-hour rating in excess of 20 Wh and lithium ion batterieswith a Watt-hour rating in excess of 100 Wh, which must be assigned to Class 9 and are subject to all ofthe applicable requirements of these Instructions;
  • Section IB applies to lithium ion cells with a Watt-hour rating not exceeding 20 Wh and lithium ionbatteries with a Watt-hour rating not exceeding 100 Wh packed in quantities that exceed the allowancepermitted in Section II, Table 965-II; and
  • Section II applies to lithium ion cells with a Watt-hour rating not exceeding 20 Wh and lithium ionbatteries with a Watt-hour rating not exceeding 100 Wh packed in quantities not exceeding theallowance permitted in Section II, Table 965-II.
Naturally we cannot do the P/I  justice with these two samples – best you use the link and download the whole report. It’s sure to ruin your St. Patrick’s Day Parade.

Our Soap Box

We rant and rave and preach about safety in transportation most of the time – this time it’s the economy, stupid (congress)

We were having a round table discussion in the office long after the closing hour a few nights ago. Of course, e-mails were still coming in, mostly about lithium batteries. Our staff (well, two of us anyway) agreed that whatever efforts regulators take to improve safety goes for naught. First of all, the battery lobby pushes to control or reduce costs. A good normal business practice for most businesses. But when air transport safety should be our primary goal, we think the manufacturers and distributors and shippers of lithium batteries should use some restraint. And the airlines would greatly reduce shippers’ desires to reduce costs by reducing hazmat fees that influence some shippers to take a very liberal interpretation of what is regulated and what is not regulated.

What the regulators and the lobbyists seem to lose sight of is: exactly who has to put those regulations into practice. Warehouse and shipping  personnel at the shipper’s facility comes to mind immediately. Then the trucker, And, finally, the air carrier’s receiving personnel. In more and more cases the receiving personnel at the airline cargo terminal are not even employees of the airline. He or she works for a subcontractor who is on the scene only because the subcontractor promises to perform the airline’s cargo handling duties cheaper than the airline can do it with their own personnel. Would you be surprised to learn that the subcontractor does not hire rocket scientists for that job? Well, neither did the airline when it used to perform that same task with its own employees.

Yet regulators continue to write new, complex regulations that require a PhD in chemistry or physics in order to understand them.  The regulations should be written so that the average person can understand them and comply with those regulations. And, cut the “cost-saving” gimmicks. All  lithium batteries should be fully regulated. Why?

At least three fatal aviation accidents point to lithium battles as the probable cause. There have been at least 60 other incidents of fires caused by lithium batteries. We are aware of at least one consumer fatality. The ICAO Working Party was convened to address safety issues concerning lithium batteries. Instead, they made the regulations even more confusing to the average shipper and forwarder.

Some of our e-mails from this morning:
  • HI,  Here is shippers packaging and her info on the e mail  See below. I am really confused, This looks like it is ok Pax with the notation on the airway bill and boxes?
  • Here attached please find a commercial invoice and MSDS from the manufacture. Please kindly find that how could we handle this material by air.
  • I was given this MSDS from the shipper. We have a box in our warehouse that contain 3 laptops and some games etc .  The lithium batteries are in the laptops. This cannot go on pax flights correct and this does not need a dg dec just the lables? I am sorry but the lithium batteries always get me nervous”
  • The reason XXXX was calling was to confirm if the attached is the correct label for the batteries.  Please advise.
  • Please take a look at attached MSDS.  Are these regulated? We need your help. We have a shipment of Dell Laptops with Lithium Ion Batteries that we are trying to export. Can you let me know based on the attached MSDS if this will have to be packed as Hazardous.
Confusion prevails. Does that guarantee safe transportation?
Have a Happy Saint Patrick's day
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