Infographic | What Makes Lithium Batteries Special?

What is it about lithium batteries that makes them so effective at powering the world around us? What is it about them that classifies them as Dangerous Goods? This infographic takes a quick look at the remarkable technology behind these high-energy power sources and offers tips for ensuring safe and compliant shipping.

Contact Labelmaster today to learn more about these and other important DG topics.

Guest Blog: ‘Tis the Season For Deadlines — Annual Taxes Overlap with Regulation Changes

By Amanda Yerke, Logic Quantum

Convert MSDS to SDS

Converting MSDSs to the new SDS format can be formidable without help. Image courtesy Logic Quantum

There are only six weeks between the April 15th tax deadline and the June 1st OSHA deadline this year. The volume of paperwork, research, and regulatory red tape involved in both deadlines can be daunting for corporations. Fortunately, your extensive experience with the IRS may help you prepare for a timely and accurate conversion to GHS standards. I’ve highlighted five of the major parallels between the two responsibilities:

1. Be Proactive
This is critical, especially when you consider how much work must be invested into filing taxes and converting MSDS’s to GHS compliant SDS’s. Evaluating your situation and organizing your documentation early will prevent a stressful scramble for information in the days before the deadline. Additionally, don’t count on an extension. With the IRS, it’s possible that your request for more time would be granted, but you won’t be that lucky with OSHA! The regulatory body has already announced that they will not be offering any extensions on the deadline, and your lack of compliance may impact shipments to your clients who are reluctant to risk OSHA violations by accepting noncompliant orders.

2. Hire a Professional
Unfortunately, legislation is often difficult to understand. The intricacies of tax law and safety regulations are complicated, and there’s a plethora of variability’s that have an impact on your compliance. Many Certified Accounting Professionals (CPA’s) charge upwards of $200 per hour, and environmental organizations charge similar rates for MSDS conversion or consulting. However, those costs can be justified by the degree of expertise these solutions offer, and by amount of time you’ll save through outsourcing the work.

3. Commit to Precision
Not only do you have to file your taxes and convert your MSDS’s, you have to do so accurately. Regardless of intent, inaccurate information can create serious consequences. If you’re audited for erroneous taxes, you’ll be penalized by the IRS. Similarly, if you refuse to comply with the GHS-aligned standard, you’re risking the possibility of rejected shipments by end customers and costly OSHA violations.

4. Embrace Transparency
In order to ensure accuracy, it’s imperative that you embrace transparency. Whether you’re working with an environmental organization such as Quantum, or a CPA who you’ve hired to compile your taxes; the accuracy of their output will only be as good as the information that you provide to them. Therefore, accept that third party options are trying to work with you, not against you. Be willing to share intimate information with your provider, whether its formulations or financial facts, in order to ensure that they can do their job accurately.

5. Reap the Benefits of Timely and Accurate Compliance
Unfortunately, complying with safety and environmental regulations doesn’t offer the same potential for monetary returns that filing your taxes does. However, there are quantitative benefits to both procedures that are invaluable to the success of your business. Complying with OSHA standards help protect you from violations, fines, and investigations in the same way that filing accurate taxes ensures a reasonable statue of limitations clock for audits. Understanding the potential consequences of noncompliance should provide incentive to get things done right, the first time!

About Logic Quantum: Quantum Compliance, a Logic Solutions Company, provides Environmental, Health and Safety (EH&S) software solutions that help businesses implement and maintain compliant and sustainable EH&S practices. Our solution offers an integrated, enterprise-wide Environmental, Health and Safety (EH&S) platform that simplifies a corporation’s EH&S information management, increases workplace safety, and reduces risk exposure to regulatory citations. www.qsdsconversion.com

Summary of USPS Publication 52: Shipping Lithium Batteries

lithium battery

Mike Pagel, Dangerous Goods Consultant, contributed to this story 

I. Introduction

On Monday, January 26, 2015, the United States Parcel Service (USPS) published a notice in the Federal Register that describes revisions to USPS Publication 52, Hazardous Restricted, and Perishable Mail.  These revisions closely align USPS requirements for shipping lithium cells and batteries with those found in both the U.S. D.O.T. and international regulations.  The Publication 52 amendments take effect from March 2, 2015.  The full text regulatory revisions were posted February 5, 2015 and can be viewed here.

II. Changes to USPS Standards

This revision significantly changed USPS requirements concerning the following:

  • Marking: Packages containing standalone lithium cells or batteries, or lithium cells and batteries packed with or contained in equipment must be marked (lithium battery handling label is authorized) to:
  • Indicate the packages contains “lithium metal” or “lithium ion” cells/batteries, as appropriate;
  • Indicate the package is to be handled with care and that a flammability hazard exists if package is damaged;
  • Indicate that special procedures must be followed in the event the package is damaged; and
  • A telephone number for additional information.
  • Note: The USPS will not require marking or documentation for button cell batteries installed in equipment, or no more than four (4) cells or two (2) batteries installed in equipment. However, for these shipment types, USPS will allow the optional use of the applicable lithium battery handling label in either domestic air or surface transport.

Note: If you choose to use the lithium battery handling label the dimensions and specifications must be as specified in 49 CFR 173.185.

  • Documentation: In addition to package markings described above, packages containing standalone lithium cells or batteries, or lithium cells and batteries packed with or contained in equipment must be accompanied by a document that contains:
  • An indication the packages contains “lithium metal” or “lithium ion” cells/batteries, as appropriate;
  • An indication the package is to be handled with care and that a flammability hazard exists if package is damages;
  • An indication that special procedures must be followed in the event the package is damaged; and
  • A telephone number for additional information.

Note: A peel away document is authorized, see Labelmaster’s Peel Away Documents here


 

LILM-R


  •  Quantity Limitations: For domestic air, packages containing standalone lithium ion cells or batteries, or lithium cells or batteries packed with or contained in equipment, the mailpiece may not contain more than two (2) batteries or more than eight (8) cells.
  • For domestic mailings the USPS is providing some practical relief for small consumer-type lithium metal cells or batteries (also called primary lithium cells or batteries) like those used to power watches, key fobs, cameras and flashlights. For lithium-ion cells and batteries with a watt-hour rating of not more than 2.7 Wh, or lithium metal batteries with lithium content no more than 0.3 grams as long as the mailpiece does not exceed 2.5 kilograms (5.5 pounds). There is no maximum number of cells or batteries per mailpiece.

Note: The new USPS quantity limitation language is not perfectly harmonized with DOT and international standards.  Unlike USPS, when lithium batteries are packed with equipment, the DOT/International regulations allow for the package to contain the minimum number of batteries required to power the equipment, plus two (2) spares.  In practice, this leads to circumstances where there are more than two (2) batteries or eight (8) cells per package.

  • Definitions: Adding and revising definitions to more closely align with other transport regulations. The additions include:
  • Describing lithium content with watt-hour rating, as is now industry standard.
  • Separate shipping descriptions for lithium metal and lithium ion cells and batteries.
  • International Prohibitions: These USPS revisions will prohibit packages required to bear the lithium battery handling label from being transported internationally. Although it is not required, marking of packages containing no more than four (4) lithium cells or two (2) lithium batteries contained in equipment is still acceptable for domestic air and surface transport.  However, packages meeting the above circumstance will be prohibited from displaying lithium battery markings when mailed internationally.

Note: In the 49 CFR as well as international regulations, marking a package containing a hazardous material – even when not required – is still permissible.  The USPS revisions will prohibit permissive marking for international shipments. Some companies choose to not take advantage of the package marking exception and apply the lithium battery handling label on packages that do not require them (e.g. a package containing a single laptop computer).  These packages will not be authorized for international mail shipments.

III. USPS – PHMSA Direct Comparison

For USPS and PHMSA (DOT) lithium battery shipments, the following general standards apply:

  • The cells and batteries must be of the type proven to meet the requirements of Part III, Subsection 38.3 of the UN Manual of Tests and Criteria;
  • All cells and batteries must be protected from damage, short circuit, movement inside of the outer packaging;
  • When lithium cells or batteries are contained in equipment, there must be a means in place to prevent accidental activation of the equipment; and
  • The packaging must be a “strong outer packaging” that is capable of preventing crushing or exposure during normal circumstances of transportation
    • Except when cells or batteries are contained in equipment, packaging must be capable of passing 1.2 meter drop test without damage to contents
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Canada Revises WHMIS to Incorporate GHS

Health Canada (more-or-less the Canadian government’s equivalent of the Occupational Safety and Health Administration (OSHA) in the United States) has officially published their adoption of the United Nations Globally Harmonized System for the Classification and Labeling of Hazardous Chemicals (GHS) into their Workplace Hazardous Materials Information System (WHMIS) (i.e. the approximate equivalent of the US Hazard Communication Standard (HCS) in the 29 CFR 1910.1200) in the official Canada Gazette (the Canadian equivalent of the US Federal Register):

http://www.gazette.gc.ca/gazette/home-accueil-eng.php

This document was published on February 11, 2015.  A transition period is authorized in the regulation under which current Material Safety Data Sheets (MSDSs) and hazard communication labels based on the extant Controlled Products Regulations may continue to be used until June 1, 2017. Safety Data Sheets (SDS’s) and GHS-based labels will be addressed in the new Hazardous Products Regulations (HPR).  Immediate compliance is authorized from the date of publication in the Gazette.  Shippers to Canada will wish to carefully review the new standards so that they can plan an orderly transition to the revised system.  Canada is the most recent nation to incorporate the revisions to hazard communication based on adherence to the UN GHS; US employers are reminded that our nation is in the midst of its own transition phase to this system, and at present the next deadline is the June 1st, 2015 requirement for chemical manufacturers to have new labeling and SDS’s in place for their products.  Extensive no-cost information resources and a wide range of product choices concerning the GHS transition in the HCS can be found on our GHS landing page:

www.labelmaster.com/ghs

Labelmaster is a full service provider of goods and services for the Hazardous Materials and Dangerous Goods professional, shippers, transport operators, and EH&S providers. See our full line of solutions at www.labelmaster.com.

Note:  Labelmaster VP/Government Affairs Bob Richard, Ph.D. contributed information resources to this notice.

PHMSA Announces Mandatory Compliance Date Extension to HM-224F for Non-Air Transport of Lithium Batteries

shipping_lithium_batteries_infographic_labelmaster_thumbnail_540Announced via the website of the Department of Transportation, Pipeline and Hazardous Materials Safety Administration (DOT PHMSA): as a result of numerous stakeholder comments, PHMSA will respond to concerns regarding difficulty in achieving full compliance by the original date set forth in the timeline mandated by the August 6th, 2014 final rule.  The agency announced that it will extend the mandatory compliance date of HM-224F for transport modes other than by aircraft.  As originally published, HM-224F requires mandatory compliance starting on February 6, 2015 unless otherwise specified.  The newly announced extension will extend the mandatory compliance date until August 7, 2015 for non-air transport of lithium cells and batteries.

View the PHMSA announcement here

Note that the August 6th final rule published under Docket No. PHMSA-2009-0095 (HM224F) amended hazard communication and packaging provisions for the safe transport of lithium batteries by further aligning the Hazardous Materials Regulations (HMR) with applicable provisions of the international regulations (including the United Nations Model Regulations, the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) and the International Maritime Dangerous Goods (IMDG) Code.  The final rule modified provisions contained in the U.S. hazardous materials transport regulations affecting the safe movement of packages containing lithium cells and batteries in commerce.

Follow the link here to view PHMSA’s August 6th 2014 federal register publication 

Further information regarding the final rule is summarized at the Labelmaster blog page located here

Labelmaster is a full service provider of goods and services for the Hazardous Materials and Dangerous Goods professional, shippers, transport operators, and EH&S providers.  Please see our full line of compliant solutions at www.labelmaster.com.