Taking charge

by Peregrine Storrs-Fox, Risk Management Director, TT Club The inherent risk in transporting lithium batteries by any mode is well documented, as have been a series of fires caused by their mishandling. It is clear that the development of green technology will lay increasing emphasis on their use in the future. Let us highlight the nature of the risks, along with the precautions that must be strictly in place for safely transporting these crucial components of modern manufacturing.

Lithium batteries, particularly lithium-ion (Li-ion), have become a preferred energy source for many products given their high power density, light weight and the ability to recharge, the last allowing to use them for several years. Today, they are used to power a variety of goods, including handheld devices (such as phones or cameras), through larger items like power tools, to increasingly larger electric vehicles (e-bikes/scooters and even seagoing ferries). The market is exponentially increasing through consumer demand and broader energy transition globally.

Inevitably, lithium batteries have been moved by all modes of transport. However, following serious incidents, revised regulatory restrictions regarding the carriage of lithium batteries by air, taking effect from 1 April 2022, may result in greater volumes being transported by surface modes. Coupled with a number of recently recorded incidents, safety concerns around the shipping of lithium batteries rightly continue to grow amongst the maritime community. Understanding the risks is therefore crucial.

Demand outpaces regulations

Lithium batteries contain stored energy utilising two different key chemistries: lithium metal/alloy and Li-ion. The former contain metal lithium and are primarily disposable, whereas the latter are rechargeable and have a different chemical composition.

The hazard that a given lithium battery presents is primarily related to the amount of contained reactive substances (including lithium and other reactive material). The sharp rise in demand has been accompanied by the supply of cheaper, poorer quality and untested batteries, including refurbished and even homemade power banks. E-commerce platforms have facilitated a global trade in these potentially lethal batteries, often circumventing international standards and regulations.

As with many successful technologies, market demand has outpaced the development of safety regulations. Since the mid1980s, lithium batteries have been classified under dangerous goods regulations for transport based on the weight of lithium contained in the cells or battery. As the technology has advanced, the amount of energy derived from the active material has increased by up to 50%, while the cell weight has reduced significantly.

Through the manufacturing stage and in preparation for transport, lithium batteries must have safeguards built in to ensure that they can withstand not only the rigours of transport but also everyday use through their expected lifetime. There are international standards that lithium batteries must meet to receive certification for safe transport, which involves passing a rigorous series of tests performed by an approved independent testing laboratory. The responsibility for testing and achieving certification rests with the shipper/manufacturer.

The rigours of transport should not be overlooked. Shock and impact damage may result in thermal stability issues, including short circuit. Defective lithium batteries have the potential to release all their stored energy instantly, resulting in thermal runaway and flammable gases. Proximity to external heat sources can also present challenges.

Given their nature and use, newly manufactured lithium batteries can be transported by themselves as individual items, packaged with products (i.e. replaceable) or within products (not intended to be removed). However, consideration should be given to reverse logistics, including used, damaged and faulty products being returned, lithium batteries being shipped as waste and those being moved for recycling. In all instances, the state of charge of any battery is a relevant factor; less stored energy generally equates to less risk.

Apart from being transported as cargo, lithium batteries are used to power many of the technological devices deployed in the supply chain to monitor and deliver efficiencies, such as GPS locators, motion detection and security, including for smart containers. Deliberations remain underway at the International Maritime Organization (IMO) in recognition of the potential hazards that these devices pose when placed in the hold of a container ship. Both regulators and the industry seek to set minimum standard criteria in the International Maritime Dangerous Goods (IMDG) Code for devices powered by such batteries.

In summary, the risks presented through the intermodal supply chain primarily exist where new lithium batteries are poorly manufactured, untested or defective. These batteries have a higher propensity to malfunction. It is also recognised that risks are higher when the batteries are being charged. At any point of handling, storage and transport, the supply chain risk is compounded by used, fully or partially charged batteries and those destined for recycling or waste. Furthermore, some incidents have revealed the use of inadequate packaging, fundamentally compromising safety.

Know your cargo

As noted above, lithium batteries, until around the mid-1980s, came within the IMDG Code Class 4.3 regulations (substances which, in contact with water, emit flammable gases). Nowadays, there are four different UN numbers for the classification of lithium cells or batteries: UN 3090 (lithium metal batteries shipped by themselves); UN 3480 (Li-ion batteries shipped by themselves); UN 3091 (lithium metal batteries contained in equipment or packed with equipment); and UN 3481 (Li-ion batteries contained in equipment or packed with equipment). These are included within Class 9 of the IMDG Code as miscellaneous dangerous substances and articles.

That said, experts and regulators were persuaded that smaller batteries present

Photo: Canva

reduced hazards compared to their larger counterparts through the supply chain. While there are various special provisions applicable to lithium batteries, the focus here is on one alone. On the basis that smaller lithium batteries present a reduced hazard, within the UN exists the SP188 regulation to enable transport under specific conditions. Where lithium batteries or cells meet these requirements, they are not subject to other provisions of the IMDG Code when offered for transportation. Notwithstanding qualification for transport under SP188, however, these batteries continue to be dangerous goods, presenting the same risks.

The SP188 qualifying criteria start by considering the weight and energy content, specifying the maximum values for lithium metal and Li-ion cells and batteries. The requirements proceed to focus on the protection of the cell or battery, setting the required packaging and considering protection from the risks of short circuit, particularly where cells or batteries are contained within the equipment.

An important point to raise here is that because those lithium batteries qualifying under SP188 are not subject to other provisions of the IMDG Code, beyond the marking of the packages (externally invisible once packed in a freight container), there is no requirement to notify the carrier specifically of the contents. Conversely, cells and batteries that don’t satisfy the requirements set out under SP188 are fully regulated for transport. Accordingly, such shipments must be declared and shipped as dangerous goods under the applicable UN number.

As with many cargo types, the majority of shippers will take all practicable steps to ensure that their cargo meets specifications, achieves certification and is classified, packaged, packed, labelled/marked and declared correctly for transport. The small – frankly criminal – minority are motivated to avoid compliance, entering cargo into the supply chain that presents a great risk to all.

Once lithium batteries, particularly those shipped under SP188, are placed into the intermodal supply chain, there is very little opportunity for the cargo to be checked, visually or otherwise, to verify compliance. Due diligence is therefore critical: know your customer, understand their processes and make sure that they are taking the required actions in preparing and declaring the cargo correctly. Accurate, unambiguous and timely communication between contracting parties is also vital, ensuring that crucial information is shared with all actors in a given supply chain.

Fat in the fire?

History illustrates that the most catastrophic losses associated with the carriage of lithium batteries have unfortunately occurred so far in the air mode. All surface modes are, however, exposed to these risks. There may be fewer reported incidents, but several container fires are suspected to have involved lithium batteries. Furthermore, the technological advances, modal shift away from air and societal appetite for electric vehicles all point to emerging risks.

Lithium-fuelled fires are challenging to extinguish, prone to thermal runaway and potentially explosive. Due to the heat generated, re-ignition once a fire has been extinguished is an additional risk, together with the impact on adjacent cargo or equipment. Furthermore, hard lessons learned by land-based fire responders, particularly relating to e-vehicles, need to be assimilated into the unforgiving maritime environment, where the crew’s capability to fight fire is already woefully strained.

Fire is an unwelcome hazard at any point during transport, storage or handling. TT Club will maintain efforts to increase awareness of the challenges faced onboard container ships and within port/ terminal areas. ‚

TT Club specialises in the insurance of intermodal operators, non-vessel owning common carriers, freight forwarders, logistics operators, marine terminals, stevedores, port authorities and ship operators. The company also deals with claims, underwriting, risk management as well as actively works on increasing safety through the transport & logistics field. Please visit www.ttclub.com for more info.