The long-awaited DOT PHMSA Interim Final Rule (IFR) enhancing the safety provisions for lithium batteries transported by aircraft appeared in the Federal Register this week on March 6th. This IFR generally harmonizes the 49 CFR with the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (regulations effective in the ICAO TI since April 1, 2016). The following is a summary of the major changes applicable to the air transport of lithium cells and batteries in the US, effective immediately:
- Prohibits the transport of standalone lithium-ion cells and batteries as cargo on passenger aircraft (does not apply to lithium-ion cells and batteries contained in or packed with equipment).
- Limits standalone lithium-ion cells and batteries to a 30% state of charge (SOC). A limited exception exists for cells/batteries used to power medical devices (requires PHMSA approval).
- Limits excepted shipments of lithium ion and metal cells/batteries to one package per consignment or overpack.
A major marking/labeling requirement is also included in the IFR that impacts road and rail shipments containing excepted lithium ion cells (≤ 20 Wh) and batteries (≤ 100 Wh) shipped in accordance with 49 CFR § 173.185(c). These types of shipments were already required to display the lithium battery mark, but now they must also display either the marking “LITHIUM ION BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT’’ or be labeled with a ‘‘CARGO AIRCRAFT ONLY’’ label. Labelmaster offers a “tab” version of the lithium battery mark that can be personalized to help meet this marking requirement as well. It’s important to note that this requirement also applies to lithium-ion cells and batteries contained in/packed with equipment where the package exceeds 5 kg of cells/batteries. The following is an example of how these types of packages were previously marked/labeled compared to how they must appear now.
A copy of the complete IFR can be viewed here.
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Do the above requirements affect shipping by ground too?
Hi Eric, note that anything PHMSA puts out affects all modes unless the item specifically addresses a mode they identify.
Hope that helps!
We normally would be shipping lithium ion cells (≤ 20 Wh) that are contained in/packed with equipment where the package is less than 5 kg of cells/batteries. Does this need markings for ground?
Please consult 49 CFR 173.185(c) for specific marking requirements in this circumstance.
Hi, is there any mandatory regulations regarding the Hazmat label dimensions? Is there any minimum size for those? Thanks
Yes. Labels and marks have required minimum sizes for both dimensions and in some cases text, depending on the specifics of any given consignment. You can find the requirements for markings in 49 CFR 172 Subpart D. You can find the requirements for labels in 49 CFR 172 Subpart E.
The Labelmaster Regs Team