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Background
There are two types of lithium batteries:
- Lithium metal batteries, which are nonrechargeable; these are referred to as primary lithium batteries; and
- Lithium ion batteries, which are rechargeable; these are sometimes called secondary lithium batteries.
Airborne Dangers
Lithium batteries have high energy densities. Under certain circumstances, they can overheat and ignite. The Federal Aviation Administration lists 144 incidents involving smoke, fire, extreme heat, or explosion that have occurred on aircraft since 1991. That may not seem like a lot in 25 years, but if you are up in the air with these batteries, one incident is one too many.
Last year, PHMSA amended regulations for shipping lithium batteries. Compliance with the regulations was mandatory as of August 2015.
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Main Concerns
Before issuing the final rule, PHMSA reviewed comments it received on the proposed rule.
Commenters expressed support for the overall goal of improving the safe transport of lithium batteries by all modes, especially by air. The commenters also stressed the need for consistency between the hazardous materials regulations (HMRs) and the International Civil Aviation Organization’s (ICAO) Technical Instructions. Several commenters suggested that even small deviations from the ICAO Technical Instructions in the transport of lithium batteries would cause significant disruptions. These commenters stated that differences between U.S. and international requirements for lithium batteries detract from safety by creating confusion and excessively complicating the detailed set of regulations that already applies to lithium battery shipments.
Air carriers and international shippers stressed the desire for a single system to eliminate errors and streamline training. In addition, the commenters claimed that any benefits associated with maintaining an option to use the current HMRs would be minor and would be more than offset by increased confusion experienced by shippers and air carriers. Additionally, commenters suggested that a failure by PHMSA to mandate the use of the ICAO Technical Instructions would create an environment where the United States permits a less stringent standard than the rest of the world, placing air carriers and pilots at increased risk and hampering enforcement of the ICAO Technical Instructions.
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PHMSA Bows to the World
The amendments address hazard communication and packaging and affect all types of transportation. However, their emphasis is on ensuring the safety of aircraft carrying lithium batteries and aligning the relevant HMRs with international standards.
The updated standards apply to shipments of primary and secondary lithium batteries within the United States.
PHMSA’s final rule for shipping lithium batteries will:
- Adopt separate shipping descriptions for primary and secondary lithium batteries.
- Revise provisions for the transport of small and medium lithium cells and batteries, including cells and batteries packed with or contained in equipment.
- Revise requirements for the transport of lithium batteries for disposal or recycling.
- Harmonize provisions for the transport of low production and prototype lithium cells and batteries with the ICAO Technical Instructions and the International Maritime Dangerous Goods Code.
- Adopt new provisions for the transport of damaged, defective, and recalled lithium batteries.