Tag Archives: Hazmat/Dangerous Goods

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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Postal Service Revises Mailing Standards for Lithium Batteries

Keeping pace with U.S. DOT’s PHMSA (U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration) the U.S. Postal Service announced changes to their respective hazardous materials standards affecting the safe transportation of lithium ion and lithium metal batteries.

According to the Notice published in today’s Federal Register (January 26, 2015, Volume 80, No. 16, pp 3996-3998), the Postal Service has revised its own standards for customers mailing lithium ion and lithium metal batteries including batteries packed with or contained in equipment. Specifically, various sections of Publication 52, Hazardous, Restricted, and Perishable Mail will be further aligned with the U.S. domestic hazardous materials regulations (HMR) located in the Code of Federal Regulations (CFR), Title 49.  Various provisions of 49 CFR covering the transport of lithium ion and lithium metal batteries were recently updated by PHMSA in August of 2014 (August 6, 2014, Federal Register Volume 79, No. 151, pp 46012-46040).  Such changes are deemed necessary to maintain alignment with the international hazardous materials transport standards.

Highlighted here are notable modifications to the standard:

  • Use of terminology describing lithium content with watt-hours for lithium-ion cells and batteries;
  • Adoption of separate shipping descriptions for lithium metal batteries and lithium-ion batteries;
  • New requirements for the transport of small lithium cells and batteries contained in equipment; and
  • New marking requirements and options for lithium batteries installed in equipment packaged with equipment and shipped without equipment.

The agency clarified the international lithium battery postal regulations which only authorize the lithium batteries contained in equipment with not more than 2 batteries or 4 cells per package. The adherence of the Lithium Battery Handling Label is prohibited by the Postal Service for mail pieces intended for international mail (see FR page 3997). US Postal Service customers preparing to transport mail pieces containing lithium batteries including those installed and packed with equipment should take note of this Federal Register Notice and should review the actual changes to Pub 52 that will be published on February 5th.  The specific revisions to Publication 52, will be published in Postal Bulletin 22408 on February 5, 2015, and can be viewed at http://about.usps.com/postalbulletin.

The changes to Publication 52 become effective March 2, 2015. You may access the entire contents of this Notice by following the link: http://www.gpo.gov/fdsys/pkg/FR-2015-01-26/pdf/2015-01346.pdf. Once the February 5th rule is published Labelmaster will provide a comprehensive summary.

For more on lithium batteries, check out our helpful resources:

Lithium Battery Shipping Information

The Changing Regulations Pertaining to Lithium Batteries

Lithium Battery Infographic

Lithium Battery Packaging Application

Battery Labels

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 including our new peel away lithium battery document.

 

The Changing Regulations Pertaining to the Transportation of Lithium Batteries

In August of 2014 the U.S. Department of Transportation (DOT) promulgated final rule HM-224F affecting the safe transport of lithium batteries[i].  DOT announced that the resultant effects from the revisions of HM-224F will “strengthen safety conditions for the shipment of lithium cells and batteries. These changes, some of which focus specifically on shipments by air, will better ensure that lithium cells and batteries are able to withstand normal transportation conditions and are packaged to reduce the possibility of damage that could lead to an unsafe situation[ii].” Continue reading

Identifying Non-hazardous Materials Effectively for Transport

train

Transporting containerized products like those aboard this BNSF train westbound at the summit of Edelstein Hill in central Illinois may require clearly identifying both hazardous and non-hazardous materials in the same shipment. (©October 2014 Paul Burgess used with permission)

The United States Department of Labor’s (USDOL) Occupational Safety and Health Administration (OSHA) published a major revision to the regulations governing hazard communication in the US 29 CFR 1910.1200 in May of 2012.  The revision, which in large measure conformed US hazard communication standards, or the HCS, to those of the United Nations Globally Harmonized System for the Classification and Labeling of Chemicals, or GHS, is becoming effective over a three year time span from December 2013 to December 2016.  As the regulation begins to mature, a variety of issues have begun to become of interest to shippers attempting to comply. Continue reading

US DOT/PHMSA Issues Interpretation Letter Regarding Class 9 Labels and Placards

In the July 20th, 2011 edition of the US Federal Register, the United States Department of Transportation’s (USDOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) published a final rule under [Docket No. PHMSA–2009–0151 (HM–218F)] under which the agency, among many other things, set forth new specifications and requirements governing the appearance of the Class 9 Hazard label. Continue reading