Page 71

BATTERY PACKAGING AND TRANSPORTATION Initially released in January 2010, the current PHMSA ruling has been revised repeatedly over the last four years to accommodate legislative changes in the US as well as international regulations related to their transport, given that shipping modes play such an important role in determining packaging specifications. Of all the thorny issues the new HM 224F ruling addresses, its most significant relief may be in its harmonization of previously conflicting regulations, in some instances marrying discrepancies between national and international requirements that have plagued players for years. Given that batteries are not always packaged in the original factory container, problems can multiply rapidly as they ship from factory to customer to test lab to packager to loading dock, and then repeat the whole process again once they’re placed in a device or product, says Rich Byczek, global technical lead, transportation technologies at Intertek. “Packaging and labelling, inner versus outer packaging — there are a lot of nuances depending on the type of battery, the size, the number of batteries, whether or not they’re shipped inside equipment, with equipment or by themselves. An EV pack presents more issues, since normally it will be shipped from a service centre or a manufacturer to an assembly plant, rather than between consumers, retailers and distributors. “This is where regulatory vigilance is critical, and the new ruling does a lot to make compliance easier in several key areas.”

Identification To date, regulations coming out of multiple agencies, despite continual tinkering, have remained stubbornly unwieldy to the point of confusion. Just determining content has resulted in elaborate parsing of definitive language. “A case in point is the matter of conflicting identification numbers for dangerous good between agencies,” says Tom Ferguson, director of technical services for Currie and Associates, a New York-based hazardous materials and dangerous goods training and consulting company. Though the UN updated its model regulations to identify lithium-ion batteries as UN3480 and lithium metal batteries as UN3090 some years ago, the US has continued to use one identification number — UN3090

www.batteriesinternational.com

“In coming up with new vocabulary, the ruling harmonizes the lingua franca of international battery language so you don’t need three dictionaries to figure out how to pack and ship a battery.” — for both lithium ion and lithium metal cells and batteries. Since these numbers must be clearly stated on the package labeling for identification during transport, confusion — and non-compliance — reigned. “When carriers and test labs received a shipment from a company with a dangerous good identified as UN3480, they would look it up in the PHMSA hazardous materials table, and finding no product identified under that number could refuse shipment of these items labelled as 3480 if they so choose,” Ferguson says. “The differences here are critical because these are completely different chemistries requiring completely different emergency responses. You would want to use water on a fire involving lithium-ion but you would not use water on a fire involving lithium metal. So the distinction is very important in transport, particularly to first responders.” Regulatory agencies, recognizing the need to resolve this over time, issued an interim letter of approval identifying the confusing language and offering temporary directives while they worked out more definitive terminology. But of course, a lot of people didn’t get that letter, he says. “And not knowing that interim changes had been made, they followed the ruling as it existed in their latest PHMSA hazardous materials table,

Rich Byczek, global technical lead, transportation technologies at Intertek

Tom Ferguson, director of technical services for Currie and Associates

HM-224F — WHAT IT RESOLVES • Replaces equivalent lithium content with watt-hours for lithium ion cells and batteries, and adds a definition of watthour. • Adopts separate definitions and shipping descriptions for lithiummetal batteries and lithium-ion batteries. • Includes a definition for a shortcircuit. • Revises provisions for the transport of small and medium lithium cells and batteries, including cells and batteries

packed with, or contained inside equipment • Revises the requirements for the transport of low production and prototype lithium cells and batteries for disposal or recycling. • Harmonizes the provisions for the transport of low production and prototype lithium cells and batteries with the ICAO Technical Instructions and the IMDG Code. • Adopts new provisions for the transport of damaged, defective and recalled lithium batteries.

Batteries International • Fall 2014 • 69

Batteries International — issue 93  

UPS embracing the latest technology — The global implications for energy storage of the latest UK TSO report — The changing rules on transpo...

Batteries International — issue 93  

UPS embracing the latest technology — The global implications for energy storage of the latest UK TSO report — The changing rules on transpo...