FREQUENTLY ASKED QUESTIONS

1.How to identify battery types and their classification

1.1 What types of batteries are classified as dangerous goods?

There are basically 4 battery families, based on their reference chemical element:

·    Lithium based
·    Lead based
·    Nickel based
·    Sodium based

1.2 What are the UN numbers of the batteries handled on this platform and classified as dangerous goods?

·       Lithium based

-      UN 3090 LITHIUM METAL BATTERIES
-      UN 3091 LITHIUM METAL BATTERIES CONTAINED IN EQUIPMENT
-      UN 3091 LITHIUM METAL BATTERIES PACKED WITH EQUIPMENT
-      UN 3480 LITHIUM ION BATTERIES
-      UN 3481 LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT
-      UN 3481 LITHIUM ION BATTERIES PACKED WITH EQUIPMENT
-      UN 3536 Lithium batteries installed in cargo transport unit

·       Lead based

-      UN 2794, BATTERIES, WET, FILLED WITH ACID
-      UN 2800, BATTERIES, WET, NON SPILLABLE

·       Nickel based

-      UN 2795, BATTERIES, WET, FILLED WITH ALKALI
-      UN 2800, BATTERIES, WET, NON SPILLABLE
-      UN 3496, BATTERIES, NICKEL-METAL HYDRIDE (only for maritime transport)

·       Sodium based

-      UN 3292, BATTERIES, CONTAINING SODIUM or
-      UN 3292, CELLS, CONTAINING SODIUM

1.3 Are button cells dangerous goods?

Not all electrochemistries can  be produced in the form of button cells, most of them are not classified as dangerous goods, with the exception of lithium metal UN 3090 and lithium ion UN 3480 button cells. Lithium button cells are dangerous goods, but given their low lithium content or their low rated capacity, they have some exemptions, particularly when installed in equipment and / or electronic boards.
The applicable transport conditions are clearly described in the e-books.
 

1.4 How to transport used batteries?

Specific special provisions and packing instructions have to be followed:
-      For lithium batteries, special provision 377 and packing instruction P909,
-      For lead-acid and NiCd batteries, the packing instruction P801,
-      For sodium batteries, the same conditions apply as for new and waste batteries.
-      The applicable transport conditions are clearly described in the e-books.
 

1.4.1. Why are there different summary sheets for WASTE LITHIUM ION CELLS/BATTERIES and CELLS AND BATTERIES FOR DISPOSAL or RECYCLING?

The differentiation is necessary as in the e-books we have identified waste batteries according to their known characteristics:

- if they are still conform and are identified of a type which has passed all tests of UN Manual of Tests and Criteria, session 38.3, they can be transported like new batteries, according to P903

- if they are not identified as compliant to a tested type, then they cannot be demonstrated as compliant to section 2.9.4 of the UN model regulation. In this case, they may be transported according to the Special provision 377 and P909

1.5 Can defective and damaged (D&D) batteries be transported?

Defective or damaged batteries, of any type, may cause safety problems during transport. The necessary measures must be taken to avoid any releases of liquids, short circuits, breakages, or overheating.
In addition, specific special provisions and packing instructions must be used for lithium batteries. The diagnosis of these batteries must be performed by competent personnel or by the manufacturer, who will also establish whether the D&D batteries are critical for transport (such as the liability to initiate a thermal runaway).
For non-critical D&D, the requirements of special provision 376 and packing instructions P908 and LP904 must be applied.
For critical D&D batteries, liable to rapidly disassemble, dangerously react, produce a flame or a dangerous evolution of heat or a dangerous emission of toxic, corrosive or flammable gases or vapors under normal conditions of carriage shall be packed and carried in accordance with packing instruction P911 or LP906
The applicable transport conditions are clearly described in the e-books.

1.6 Can prototype batteries be transported?

With the exception of lithium batteries, prototype batteries follow the same transport rules as production batteries.
Prototypes of lithium batteries must in practice follow the indications of special provision 310 and the packing instructions P910 and LP905; each cell or battery shall be individually packed in an inner packaging and placed inside an outer packaging.
Each inner packaging shall be completely surrounded by sufficient non-combustible and electrically non- conductive thermal insulation material to protect against a dangerous evolution of heat.
Outer packagings shall conform to the packing group II performance level.
The applicable transport conditions are clearly described in the e-books.

2. How to choose and use marks and label

2.1 What are marks and labels?

Marks and labels represent a coded communication system that highlights the presence of dangerous goods inside thepackages being transported. The mark identifies the goods while the label identifies its hazard characteristics (classes).

           

2.2 What are the marks used for the batteries?

Marks are 4-digit numbers preceded by the letters UN, for example:

UN 3480
UN 2794
 
There are other marks that indicate other transport conditions for batteries or their components:


Lithium battery mark for small excepted lithium batteries

Environmentally hazardous

Limited quantities
Road and maritime air

           

2.3 What are the labels used for the batteries?

Lithium NiMH Lead-acid and NiCd Sodium

Marks and labels used in battery transport are clearly described in the e-books

           

3.  How to choose the packagings for batteries

3. 1 Good quality and strong packagings

Dangerous goods shall be packed in good quality packagings which shall be strong enough to withstand the shocks andloadings normally encountered during carriage, including trans-shipment between cargo transport units and betweencargo transport units and warehouses as well as any removal from a pallet or overpack for subsequent manual ormechanical handling.

           

3. 2 Prevent any loss of dangerous goods

Packagings shall be constructed and closed so as to prevent any loss of contents when prepared for transport whichmight be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure(resulting from altitude, for example)

           

 3.3 Closure of Packagings

Packagings shall be closed in accordance with the information provided by the manufacturer.

           

3.4 Packagings materials in contact with dangerous goods

Parts of packagings which are in direct contact with dangerous goods:

  •  shall not be affected or significantly weakened by those dangerous goods;
  • shall not cause a dangerous effect e.g. catalysing a reaction or reacting with the dangerous goods;
  • shall not allow permeation of the dangerous goods that could constitute a danger under normal conditions ofcarriage.
     

Where necessary, they shall be provided with a suitable inner coating or treatment.

3.5 Approved Packagings

Unless otherwise provided in the transport regulations, each packaging, except inner packagings, shall conform to adesign type successfully tested in accordance with the approval requirements.
 
Each approved packaging shall bear UN mark of packagings followed by a code (letters+numbers) which describes theircharacteristics, which are durable, legible and placed in a location and of such a size relative to the packaging as to bereadily visible.

Example of a new fibreboard box:


The e-books describe the packaging required in the various transport conditions of batteries.

 3.6 Is pallet shipment without packaging possible for lithium batteries?

Yes it is possible for new lithium batteries with a gross mass of 12 kg or more, employing a strong, impact resistantouter casing. Batteries shall be protected against short circuit and shall be secured to prevent inadvertent movement,and the terminals shall not support the weight of other superimposed elements, as described in P903.
 
The same conditions are applicable to used lithium batteries if they are still able to meet the requirements of each testof the Manual of Tests and Criteria, Part III, sub-section 38.3.

4. Testing requirements for lithium batteries

4.1 How do I know if lithium batteries I'm going to purchase meet the requirements of the “UN Manual of Tests and Criteria,Part III, subsection 38.3”?

Check it with the manufacturer or distributor of the batteries; they have to provide the “test summary” according to UNManual of Tests and Criteria 38.3.; this information may be also reported in the product information sheet .

4.2  If they use lithium cells that have already been tested, do lithium batteries have to be tested?

Yes. Batteries shall be proved to meet the testing requirements of the Manual of Tests and Criteria, part III, sub-section38.3, irrespective of whether the cells of which they are composed are of a tested type or not.

4.3  If my cells and batteries must always be tested prior to shipping, how do I ship them for testing?

Dangerous goods regulations foresees exceptions or special provisions for the shipment of cells and batteries fortesting purposes. Road and maritime transportation of prototype cells and batteries do not require any prior approvals,but are subject to stringent packaging requirements; air transportation is subject to approval of the competent authority.

4.4 What Wh rating have to be marked on batteries or battery packs if the manufacturer/assembler reduces, for safety reason,the charging voltage although the battery cells inside are capable to be charged at higher voltage (and thus contain a higherWh energy)?

UN transport regulation and UN Manual of tests and Criteria, section 38.3 clearly states that Wh rating (Nominalenergy) is calculated by multiplying Nominal Voltage by Rated Capacity (Ah).

5. Lithium batteries in/with equipment

5.1 I have a shipment of electronic equipment containing lithium batteries, is it classified as a dangerous good?

Yes, but the conditions are less restrictive of the individual batteries and vary according to the characteristics and thenumber of elements and batteries

5.2 Are there different requirements in the shipment of individual batteries and appliances or equipment containing batteries?

Yes, batteries shell be protected from short circuit and when installed in equipment or machinery they shell be protected fromunintentional activation during transport. In the case of lithium batteries they shall be assigned to different entries whencontained in equipment and also packed with equipment.

5.3 What are the rules for consumers travelling with devices powered by Lithium and Lithium Ion cells and batteries?

Provisions for consumer transport of batteries and battery powered devices are covered in the ICAO TechnicalInstructions as well as the IATA DGR. Information can be found in the eBooks

6. Batteries shipping with charges

6.1 Is the transport of lithium ion battery and charger in the same box considered "lithium battery packed  with equipment"?

No, a charger is not “equipment” because the battery is not used to power this device. Therefore, a charger packedwith a Li ion battery would be a UN 3480 shipment.

6.2 Is the transport of lithium ion battery installed in the charger considered "lithium battery contained in equipment"?

No, a charger is not “equipment” because the battery is not used to power the device. Therefore, a charger containinga lithium ion battery would be a UN 3480 shipment.

7. Consignor obligations

7.1 What are the obligations of the battery consignor?

Anyone offering a battery for shipment (alone, installed in or packaged with equipment), is responsible forensuring that the battery itself meets all the appropriate requirements of the appropriate shipping regulations.This includes testing, marking, labelling, packaging and documentation requirements.

7.2 As a shipper of dangerous goods, do I need training?

Yes, all persons involved in the preparation and shipping of dangerous goods shall be trained in the requirementsgoverning the carriage of such goods, appropriate to their responsibilities and duties.

8. Distributors and Re-packers obligations

8.1 Do distributor or re-packers that ships batteries have  obligations?

Yes, as a consignor offering a battery for shipment (alone, installed in or packaged with equipment), isresponsible for ensuring that the battery itself meets all the appropriate requirements of the appropriate shippingregulations.

9. Multimodal transport

9.1 The battery classification as dangerous goods apply to road as well as to sea and air transport mode?

Yes, the classification is made at UN level, but every transport mode may introduce specific restrictions orexemptions.

9.2  The exemptions applicable to Road transport mode apply to Sea and Air transport mode as well?

No, usually sea and air transport regulations are more restrictive and do not provide exemptions.

10. Safety instruction and the driver

10.1 How the driver should use safety instruction in writings (ADR)

The carrier shall provide the vehicle crew with the instructions in writing in language(s) that each member can readand understand before the commencement of the journey.
 
The carrier shall ensure that each member of the vehicle crew concerned understands and is capable of carrying out theinstructions properly.
 
Before the start of the journey, the members of the vehicle crew shall get informed of the dangerous goods loaded andconsult the instructions in writing for details on actions to be taken in the event of an accident or emergency.

The complete description of the information required by the different transport modes are available in the e-books

11. Trasport documents

11.1 How to fill transport documents

The transport document is prepared by the shipper and contains the information necessary to identify the dangerousgoods and the transport details.
 
There are different models for the different transport modes ADR-IMDG-IATA, the following data are common to all ofthem when batteries are transported:

  • he UN number preceded by the letters "UN"
  • the proper shipping name
  • the label model number or class
  • the number and a description of the packages
  • the total quantity of each item of dangerous goods
  • the name and address of the consignor;
  • the name and address of the consignee(s).
     

Note: batteries are articles, so they have no packing group assigned.
 
The complete description of the information required by the different transport modes are available in the e-books

12.  Transport in partial exemption 1.1.3.6 ADR

12. How to transport in partial exemption 1.1.3.6 ADR

Chapter 1.1.3.6 ADR is a partial exemption related to quantities of dangerous goods carried per transport unit.
Dangerous goods are assigned to transport categories 0, 1, 2, 3, or 4, batteries and electrolytes are assigned to the following categories:
category 2 > UN No. 3090, 3091, 3480, 3481, 3292, 2796, 2797
category 3 > UN No. 2794, 2795, 2800
 
(a)  For these categories the exemption limits (weight that must not be exceeded on the whole vehicle) are as follows:

category 0   > not exemption
category 1 > 20 kg
category 2 > UN No. 3090, 3091, 3480, 3481, 3292, 2796, 2797 > 333 kg
category 3 > UN No. 2794, 2795, 2800  > 1000 kg
category 4 > unlimited


Where dangerous goods of different transport categories are carried in the same transport unit, you have to refer to chapter 1.1.3.6 and evaluate the exemption limits.