Regulatory Helpdesk: March 5

Batteries, Batteries, and more Lithium Batteries

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Why do I need an SDS for a Laptop Battery?

Q. We are shipping used laptops with batteries in the units from the US to HK via air. There are multiple manufacturers and models, are (M)SDS sheets required for each model? Our forwarder is requesting them in order to provide pricing.

A. To answer your question, it would depend on why the forwarder is requesting them. They may be asking for them to meet the written emergency response requirements. However, they could be asking for them for classification purposes to prove which part of the packing instructions these meet.

The SDS could tell them the watt-hour rating which would then drive which part of the instruction to use. Forwarders and carriers have a lot of leeway. I can only speak to what the regulations say. There is nothing in 49 CFR or IATA that indicates you must use an SDS. Most people tend to default to them because they meet so many parts of the regulations in one place.

Manufacturer’s Packaging (Lithium Battery)

Q. Should I remove the manufacturer’s packaging from lithium ion batteries being shipped by air under PI 965 section 1A?

A. Not unless you have another inner package that you are using. Although types are not specified, PI 965 requires inner packagings.

Lithium Battery on a Skid

Q. Can a large lithium ion battery be shipped on a skid without UN specification packaging?

A. Although 49 CFR and TP14850 allow for shipping batteries of 12 kg or more in slatted crates or on skids, the references are in the context of non-bulk (i.e., small means of containment standards). Thus, if the battery is large enough to require bulk/large means of containment packaging, a special permit/equivalency certificate would be required. IATA limits battery weight to 35 kg; and even batteries from 12 – 35 kg require state-of-origin authorization.

Is an IATA DGR Required? (Air)

Q. Do I need a copy of the IATA DGR to ship UN3481 meeting the exemption criteria?

A. IATA DGR 1.6 indicates written instructions and other aspects of training necessary for those shipping lithium batteries under s II of PI 965 – 970. The shipper requires procedures that are compliant with the PI. The validity of the training/procedures would be difficult to justify if there isn’t a reference copy of the regulations available.

We certainly did receive a lot of questions regarding lithium batteries this week. For other resources on lithium batteries check out ICC’s lithium battery solutions.