Recent DOT Activities On Lithium Battery Regulations Dr. Charles H. Ke Chief, Science Group Office of Hazardous Materials Technology Pipeline and Hazardous Materials Safety Administration (PHMSA) U.S. Department of Transportation
49 CFR 173.101 and 173.185 Lithium battery: cells and batteries containing lithium in any form, including lithium polymer and lithium ion cells and batteries. It includes PRIMARY and RECHARGEABLE batteries Two shipping names: UN 3090: Lithium Batteries UN 3091: Lithium Batteries Contained In Equipment or Lithium Batteries Packed With equipment
Recent DOT Activities on Lithium Batteries April 2, 2002---HM-224C, Notice of proposed rulemaking December 15, 2004---HM-224E, Interim final rule
Proposed Revisions of 49CFR (HM-224C) UN Model Regulations revised Li Bat provisions in 2000 which were implemented in ICAO, IMDG regulations in 2003** Notice of proposed rulemaking, HM-224C (April 2, 2002) intended to incorporate the 2000 UN revisions **: LAX incident of April 28, 1999 involving Li batteries
Proposed Revisions of HM-224C 1. Changes to test methods 2. Revisions to exceptions for small batteries 3. Eliminate the 5 g for cell and 25 g for battery exception 4. Exceptions for aircraft passengers and crew (175.10)
Proposed revisions in HM-224--- Continued 1. Changes to test methods: Adopting the revised UN test requirements described in Section 38.3 of the UN Manual of Tests and criteria, Rev. 4 6 tests (T.1 to T.6 in Rev. 3) to 8 tests (T.1 to T.8 in Rev.4)
Proposed Revisions in HM-224C--- Continued 2. Changes for excepted small size batteries: Limit of lithium content: 1.0 g for cells (1.5 g for lithium ion), 2.0 g for batteries (8.0 g for lithium ion) Must meet the testing requirements Each package contains more than 24 cells or 12 batteries be: (i) marked, (ii) accompanied with a document, (iii) limited to 30 Kg (gross wt.), and (iv) pass 1.2 meter drop test
Proposed Revisions in HM-224C--- Continued 3. Eliminate 173.85 (c)(49 CFR, Oct.1, 2004 edition)--- exception for 5 g cells and 25 g batteries
Proposed Revisions in HM-224C--- Continued 4. Changes to175.10 (air regulations): Allow passengers and crew to carry consumer electronic devices containing lithium (lithium ion) cells or batteries for personal use on board an aircraft Allow spare battery to be carried in carry-on baggage: 1 battery with not more than 2 g lithium content; up to 2 lithium ion batteries 8 to 25 g equivalent lithium content
Proposed Revisions in HM-224E Prohibit transportation of primary lithium cells and batteries, as cargo, aboard passenger aircraft Packages containing lithium cells and batteries that are excepted by 173.185(b) or (c) can only be transported by cargo-only aircraft and the package has to be marked with “PRIMARY LITHIUM BATTERYIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT”
Proposed Revisions in HM-224E---Continued Limit the quantity of secondary lithium cells and batteries aboard passenger aircraft to 5 Kg (gross weight) per package Primary cells and batteries excepted by 173.185(b) or (c) contained or packed with equipment are allowed on board passenger aircraft but limited to 5 Kg (gross weight) per package
Proposed Revisions in HM-224E---Continued Secondary lithium cells and batteries are allowed on board passenger aircraft but limited to 5 Kg (gross weight) per package
Proposed Revisions in HM-224E---Continued Lithium cells (5 g Li content) and batteries (25 g Li content) installed in or as spare part for personal use electronic devices or medical devices are allowed in carry-on or checked baggage aboard passenger aircraft This rule (HM-224E) applies to both domestic and foreign transport aboard passenger aircraft
Contact Information Charles Ke PHMSA, DOT Tel: 202-366-4545 E-Mail: Charles.Ke@DOT.Gov www.hazmat.dot.gov