Editor’s note: The Coordinating Committee for Automotive Repair (CCAR) is a non-profit organization with a focus on the automotive industry and its needs for safety and hazardous material compliance and training. The letter’s author, Steve Hunt, is CCAR’s business partner at ShipMate.
Letter writer sheds light on additional recommendations and observations to ensure that EV packages are properly prepared for transports
I read with great interest the article EV Hazards: Preparing an EV Battery for Shipment that appeared in AftermarketMatters.com on October 4, 2022.
The article suggests that service technicians assess the EV batteries risk protocol before packaging it and describes procedures on how to assess risk in preparation for shipment. The article suggests that the batteries’ risk be assigned to either Critical Risk, High Risk, or Average Risk and offers specific questions and assessment criteria measuring Physical Damage or Thermal Stability.
The article also stated that “batteries that have all their parts, and all parts are secured and protected as necessary, are good to go for shipping.”
It is here that I wish to offer some additional recommendations and observations to ensure that the packages are properly prepared for transport in conformance with the applicable dangerous goods regulations.
First, however, I must state that the article did not specify which type of EV battery that was being considered. EV batteries can be classified in several different ways. For example, older or first generation EV batteries may be regulated as: UN3496, BATTERIES, NICKEL-METAL HYDRIDE, 9, whereas newer EV batteries are likely to be classified as: UN3480, LITHIUM ION BATTERIES, 9.
It is important to differentiate between the two types as the former is only regulated for transport by vessel (in specific quantities) and when undamaged. The latter is regulated by surface (road and rail), vessel, and cargo aircraft and is specifically forbidden for transport aboard passenger aircraft. The requirements for marking, labeling and UN approved packaged are also considerably different depending upon its classification.
In all cases, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) Hazardous Materials Regulations (and other equivalent international standards) specifies in 49 CFR 173.21 that “…electrical devices, such as batteries and battery-powered devices, which are likely to create sparks or generate a dangerous evolution of heat, unless packaged in a manner which precludes such an occurrence” be classified as Forbidden Materials and not offered into transportation.
Therefore, EV batteries, regardless of type, that have been assigned as a Critical Risk or High Risk in accordance with the criteria outlined in the article should, therefore, not be offered for transportation into commerce, but rather managed as universal or hazardous waste (depending upon state or federal waste classification criteria) and be properly packaged, managed, and transported by licensed waste handling and transportation professionals.
Nickel-Metal Hydride Batteries
Undamaged NiMH batteries, assigned as Average Risk, should be packed in a leakproof inner receptacle (e.g., plastic bag) and then tightly packed in a strong outer packaging such as a non-specification tri-wall fiberboard box, plastic box, or wooden or metal crate. These need not be marked and labeled as dangerous goods and are not subject to shipping papers (dangerous goods declarations) except when offered for transport by vessel.
Lithium Ion Batteries
Undamaged lithium ion batteries, assigned as Average Risk, should be packed in a leakproof inner receptacle (e.g., plastic bag) and then tightly packed in a strong United Nations’ approved specification packaging such as a fiberboard box, plastic or metal box, designed and certified to Packing Group II performance standards. These packages must be marked appropriately with the UN identification number, proper shipping name, and labeled appropriately with the Class 9 lithium battery label. In addition, they should also be marked FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT or labeled with the Cargo Handling Only label to prevent them from being cross-docked onto a passenger aircraft.
For transport by air, additional marking and other requirements will apply (e.g., NET QTY, < 30% State-of-Charge). It is also recommended that these packages be marked with the Energy (or Watt-hour) rating for all modes.
Damaged, Defective and Recalled Batteries
Lithium-ion batteries which are assigned to a Critical Risk should be considered as Forbidden Materials and prohibited for shipment. Those which are damaged or defective and which are assigned to High Risk according to the articles’ criteria, but which are not likely to create sparks or generate a dangerous evolution of heat are subject to the requirements of 49 CFR 173.185(f) for Damaged, Defective and Recalled (or DDR) batteries. Similar standards are also found in the international equivalents.
Lithium cells or batteries that have been damaged or identified by the manufacturer as being defective for safety reasons (or DDR batteries), that have the potential of producing a dangerous evolution of heat, fire, or short circuit (e.g., those being returned to the manufacturer for safety reasons) may be transported by highway, rail or vessel only, and must be packaged as follows:
- Each cell or battery must be placed in individual, non-metallic inner packaging that completely encloses the cell or battery;
- The inner packaging must be surrounded by cushioning material that is non-combustible, electrically non-conductive, and absorbent; and
- Each inner packaging must be individually placed in one of the UN approved specification packagings outlined in the 49 CFR 173.185(f) standard at a Packing Group I performance level.
In addition to the required marks and labels for lithium ion batteries, the outer package must be marked with an indication that the package contains a “Damaged/Defective Lithium Ion Battery” and/or “Damaged/Defective Lithium Metal Battery” as appropriate. The marking required by this paragraph must be in characters at least 12 mm (0.47 inches) high.
DDR batteries are NOT accepted for transportation by air under any circumstances.
Now, it is important to note that a lithium ion battery which is assigned to Average Risk may still be subject to transportation requirements as a DDR battery if it has been recalled by the manufacturer.
In all cases, persons that prepare hazardous materials for transportation in commerce, including packing and packaging, marking or labeling, or preparing shipping papers must also receive hazardous materials transportation training including: (a) General Awareness & Familiarization; (b) General Safety; (c) Security Awareness; and (d) Function-Specification training. Training must be provided for all hazardous materials, as defined by DOT rules, within 90 days of assignment to a hazardous materials transportation or pre-transportation function and every three years thereafter (two for air transport).
Online hazardous materials transportation training is available through the Coordinating Committee for Automotive Repair’s (CCAR’s) HazmatU Learning Management System at www.hazmatu.org or by calling +1 (888) 476-5465.
Additional questions regarding the transportation of EV batteries and other hazardous materials can be directed to the Steve Hunt by email at firstname.lastname@example.org or phone, 1-(310)-370-3600.
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