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PHMSA Updates 49 CFR Lithium Battery Air Regulations

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(@jimp)
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[Courtesy of Scott Dunsmore, Lion]

New Lithium Battery Markings/Labels for 2019

For those of us who experience the joys of shipping lithium batteries, you have probably come to the realization that the regulators like to change the rules regarding them and do that on a frequent basis.  Just when you finally get your operations in order, they change what is required.

Consider this a friendly reminder to start using the new lithium battery marks and labels!

Get training to ship lithium batteries by ground, air, or ocean in 2019. The Shipping Lithium Batteries Online Course covers the latest rules that lithium battery shippers must know. 

The Two Year Phase-In Period is Over

Hopefully, you are already aware that there are new marks and labels for lithium batteries.  These new communications were added to all the different sets of regulations (whether DOT, IATA, or IMDG) at the start of 2017. 

As part of that rulemaking, they gave a two-year transition period to start using the new marks and labels.  During that two-year period, you could use either the “old” marks and labels or the new updated ones.
As of January 1, 2019, that transition period has ended.  As such, you can no longer use the “old” versions; you must use the newest options.

Comparing the “Old” and “New” Versions

Below are some visuals just to make sure you are using the correct marks and labels now that 2019 has rolled around.

Shipping Excepted Lithium Batteries

If you ship what we call “excepted” lithium batteries, you will need to start using the “lithium battery mark” (seen below).  Excepted cells/batteries are defined as:

  • Lithium ion cells ≤ 20 Wh
  • Lithium ion batteries ≤ 100 Wh
  • Lithium metal cells ≤ 1 gram of lithium
  • Lithium metal batteries ≤ 2 grams of lithium

As an aside, the DOT has higher limits for ground only shipments (previously called “medium” sized batteries).

Here is the NEW “lithium battery mark” now mandatory for excepted sized batteries:
New lithium battery marking for 2019YES! 
As a result of this new mark, you CAN NO LONGER USE the old “lithium battery handling label” seen here:
Old lithium battery mark pre 2019NO!

Shipping Fully Regulated Lithium Batteries

If you ship fully regulated lithium batteries (which are those larger than the limits listed above), there are many marks and labels that will need to go onto your package including the proper shipping name, UN identification number, etc.

In addition, you will need to place a Class 9 label on the package, and with the 2017 rulemaking, there is a new Class 9 label specific for lithium batteries. 

As such, you MUST use the following Class 9 Lithium Battery Label:
Lithium battery class 9 label fully regulated ion metalYES!

You are NOT allowed to use the “generic” Class 9 label shown here:
Old lithium battery label class 9 lithium ion batteriesNO! 

As a reminder, this “generic” Class 9 label will still be used for other “Miscellaneous” hazards, just not lithium batteries anymore.

This topic was modified 5 years ago by Jim Powell

   
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