Massive UN Lithium Battery Transport Proposal this Summer

Urgent UN Proposal for Lithium Battery Regulation, June 2024

Author: Jim Powell, CDGP, President, dgtraining.com and Vice-Chair, Dangerous Goods Trainers Association, Inc.

Would you like to hear a 7-minute audio recap of this instead just click on the blue speaker icon or just review the tables below and click here.

Most of the editorial information below is my summary of PARTS of the UN document which is over 6000 words long.  Please read the original document linked below for the actual detail of the proposal.

In this summer’s UN meeting of the Sub-Committee of Experts on the Transport of Dangerous Goods (64th session), in which DGTA is a participant, this proposal will be presented to outline a system of reclassification of Lithium and Sodium Batteries for transport according to new safety classification criteria.

The idea which has been studied by the Informal Lithium Battery Working Group represents a huge potential change in lithium battery and sodium-ion battery transport regulations if adopted. You can click on one of the second link above to download the document.

The document presents a hazard-based classification system for lithium batteries, including lithium metal, lithium ion, and sodium ion cells and batteries. It proposes various hazard categories and new UN numbers for cells and batteries, while discussing necessary safety requirements during the transportation of these batteries.

The proposed hazard classes and their criteria are summarized in the tables below.  There are great implications for everyone in the supply-chain involving Dangerous Goods Transport, not the least involving trainers – it will be significantly more challenging to provide comprehensive yet easy-to-understand education to manufacturers, shippers, forwarders and carriers if and when these proposals are adopted.

(Editors note: in the table below Jim Powell, DGTA added the color coding for the readers convenience and comprehension, it has nothing to do with the official proposal). Listed below are the categories for the new hazard designations and after that table, we’ve included the proposed new UN numbers.)

New UN numbers (again, the colors were added by the author of this article, not part of the UN proposal.)

There is an equivalent table for Sodium Batteries (below) as well

As for further development of this proposed rule, the working group will continue investigating undecided points, while test conditions are still being validated through testing, and additional modifications to the test protocol are possible. The Sub-Committee will also discuss further topics, such as packing instructions, testing of cells or batteries in packaging, or testing of packaging.

I suspect that there will be other consequences on the carrier side of things. It would not be surprising for different carriers to accept some but perhaps not all types of batteries under this new system – right now it’s pretty binary, they either accept or don’t accept lithium batteries (though many draw a distinction between those packed with or contained in equipment as opposed to “loose” batteries.  Perhaps one carrier would except 94E though The proposed amendments in the document would have significant implications for training, marking, labeling, and documentation requirements under the new hazard-based classification system for lithium and sodium ion batteries:

1. Training:

• Personnel involved in the transport of these batteries would need to be trained on the new classification system, hazard divisions, and associated requirements.
• Training materials would need to be updated to cover the new UN numbers, packing instructions, special provisions, and testing procedures.

2. Marking and Labeling:

• Packages containing lithium or sodium ion batteries would need to be marked with the new appropriate UN numbers based on the hazard division (e.g., UN 4000 to UN 4031 for lithium batteries, UN 4100 to UN 4115 for sodium ion batteries).
• Labels would need to be updated to include the new hazard divisions (94A to 94H, 94X for lithium batteries; 95A to 95H, 95X for sodium ion batteries). The document proposes that the hazard division may be included on the labels.
• The lithium battery mark (Figure 5.2.5 in the current regulations) would need to be updated to include the new UN numbers and hazard divisions.

3. Documentation:

• The transport document would need to include the new UN numbers and proper shipping names based on the hazard division.
• For batteries transported at a specific state of charge (SOC), the maximum SOC would need to be indicated on the transport document.
• The test summary would need to be updated to include the results of the new categorization tests (T.9 to T.13) and the SOC at which the cell or battery was tested, if applicable.

There might have to be some substantiation of the shippers/manufacturer’s classification of these items (i.e. Lithium Battery Test Summary Report)

4. Packaging:

• New packing instructions are proposed for certain hazard divisions (e.g., P9XX for UN 4005, UN 4013, UN 4105, and UN 4113).
• Existing packing instructions (e.g., P903, P908, P909, LP903, LP904) would need to be updated to reflect the new UN numbers and hazard divisions.

Implementing these changes would require significant effort from battery manufacturers, shippers, carriers, and regulators to ensure compliance with the new system. A transitional period would likely be necessary to allow stakeholders to adapt to the new requirements.

But this summer’s UN meeting is the start of the process of getting from research to implementation and the only thing we can be sure of is that it’s likely to be a long process to determine how much of this proposal will actually be adopted and implemented.

Again, my summary of all this is on behalf of the Dangerous Goods Trainers Association.  All this is just the start of taking these proposals based on years of work on the part of the Lithium Battery Working Group at the UN and bringing it into the subcommittee for consideration by the larger body.

Thanks very much.

Jim Powell, CDGP

Vice Chair, Dangerous Goods Trainers Association, Inc.