CTACHMM – GENERAL MEETING – DEC 2014 - DOT REGULATIONS FOR LITHIUM METAL AND LITHIUM-ION BATTERIES - PROPOSED CT BATTERY RECYCLING LAW INCIDENTS Laptop showing result of Li-Ion fire Lithium-ion batteries considered source of fire Carry 81,000 Lithium batteries A great FAA & CAA training video of Lithium batteries on a passenger aircraft. http://www.youtube.com/watch?v=h0 5hn1nfe3M AGENDA • General Definitions Battery • Chemistry • Lithium Metal • Lithium-Ion • • DOT Definitions Batteries • Batteries With Equipment • Batteries In Equipment • • DOT • Shipping Names • Packaging • Labeling • Training •Personal Travel •Example •CT Battery Recycling Laws DEFINITIONS • • Battery – a device containing an electric cell or a series of electric cells storing chemical energy that can be converted into electrical power, usually in the form of direct current. Chemistry • Primary – used until “dead” and then discarded • Alkaline Zinc Air Zinc Carbon • Lithium Metal • NiOOH • • • Rechargeable – electrochemical reactions are electrically reversible (use & recharge) • Ni-Cad NiMH Lead Acid • Lithium-Ion • Fuel Cell • • LITHIUM METAL BATTERIES • • • • What are Lithium Metal Batteries? Higher power batteries, than alkaline One time use; throw away batteries, not rechargeable Coin cells, cylindrical (camera) batteries 3V combination LITHIUM-ION BATTERIES • • • What are Lithium-ion Batteries? Thinner/flatter batteries Rechargeable, multiple use Cylindrical, pack or pouch batteries • Pouch batteries • • • MP3 Phones/pads Non-removable battery SHIPPING MODES Ground – DOT US DOT 49 CFR covers all modes of transport within the US Most carriers accept IATA for air within US Air – IATA International Air Transport Association (pilots & carriers) New regulations for personal travel ICAO – International Civil Aviation Organization (NGO body under the UN that coordinates HazMat shipping by Air) Boat – IMDG International Maritime Dangerous Goods DEFINITIONS All Modes of Shipping have these 3 Shipping Names for both Lithium Metal & Lithium-Ion Batteries: UN3090 UN3480 Batteries – By themselves, nothing else in the container Batteries with Equipment – Batteries & devices separate in the same container Batteries in Equipment - Batteries IN the device DOT – 172.101 TABLE UN/Proper ship names consistent with international standards LITHIUM METAL CELLS & BATTERIES - CHANGES • • Clarification that lithium cells & batteries are subject to UN tests. (38.3) A requirement that lithium cell & battery manufacturers create a record of satisfactory completion of the UN testing prior to offering the cell or battery for transport. Maintained for as long as the battery design is shipped & 1 year after. LITHIUM-ION BATTERIES - CHANGES • No more Equivalent lithium content conversion. • • Special Provisions 188 & 189 – deleted 173.185(c) SPECIAL PROVISIONS, CON’T • Special provision not listed in 172.101 table – most are in the packaging requirements – similar to IATA & IMDG • • • • • • • • • • SP29 – low production lithium cells & batteries SP134 – vehicles powered by wet batteries SP188&189 – replaced with 173.185© SP190 – deleted SPA51-aircraft batteries transported on passenger aircraft as cargo SPA54- applicable to lithium batteries over 35 KG SPA55-prototype batteries shipped by air SPA100-Not applicable SPA101 – changed to be comparable to ICAO Technical Instructions SPA103&A104 –Lithium=ion packed with or in equipment been deleted SMALL & MEDIUM BATTERY EXCEPTIONS/ SPECIAL PROVISIONS DURACELL SDS – SHOWS LITHIUM CONTENT PER CELL & PER BATTERY PACKAGING 49CFR 173.185(C) • • • • Exceptions for highway, rail & vessel for small cells & batteries (& equipment packed with or containing them) consistent with SP 188 from IMDG Code Exceptions for air for small cells & batteries (& equipment packed with or containing them) consistent with Section II of PI 965-970 Exception for medium cells for highway & rail has no equivalent in the international standards – the US is unique. PHMSA generally adapted changes that are consistent with international standards. • New regulations no longer have the “12 batteries or 24 cells no hazard mark or documentation was required” relief. PACKAGING CON’T – HIGHWAY/RAIL • • • Except small lithium metal cells packed with or contained in equipment in quantities less than 5 Kg Medium lithium-ion & lithium metal Inner packaging must prevent short circuits of batteries/cells • • • Ziplock baggies, taping terminal ends, individually bubble wrap, etc. Except when cells or batteries are packed with or contained in equipment, each package must not exceed 30 kg GROSS weight Except when cells or batteries are packed with or contained in equipment, each package must be capable of withstanding a 1.2 meter drop test in any orientation without damage – doesn’t need to be UN Spec Packaging PACKAGING CON’T – HIGHWAY/RAIL • Except for a packaging containing button cell batteries installed in equipment (including circuit boards), or no more than 4 lithium cells or 2 lithium-ion cells or batteries – outer package must be marked: CONTAINS LITHIUM METAL OR LITHIUM-ION BATTERIES/CELLS • PACKAGE TO BE HANDLED WITH CARE & FLAMMABLE HAZARD EXITS IF THE PACKAGED IS DAMAPED • SPECIAL PROCEDURES MUST BE FOLLOWED IF THE PACKAGED IS DAMAGED • PHONE NUMBER • ADDITIONAL REQUIREMENTS IF PACKAGED IS SHIPPED BY AIR In/with equipment: # that powers the equipment + 2 spares – no more than 5Kg lithium cells/batteries TRAINING Each person who prepares a package for air transport in accordance with these air exceptions must receive “adequate instruction on these conditions and limitations, commensurate with their responsibilities.” Historically, this phrasing has been interpreted to mean that full haz mat training is not required. PACKAGING EXCEEDS QUANTITY OR WEIGHT Exceeds quantity or weight – CLASS 9 dangerous goods – fully regulated EXCEPT: No more than 2.5 kg lithium metal cells or 10 kg lithium-ion cells Then not subject to UN performance packaging requirements When Class 9 , Lithium battery handling Mark & Cargo Aircraft Only Label OR “PRIMARY LITHIUM BATTERIES – FORBBINE FOR TRANSPORT ABOARD PASSENDGER AIRCRAFT” Dangerous Goods Declaration filled out LITHIUM CELLS/BATTERIES SHIPPED FOR RECYCLING 173.185(D) Relief applies to all cells & batteries and equipment containing them when they are transjported by highway. Exceptions from UN testing, recordkeeping and UN performance packaging requirements. Small & Medium cells/batteries that meet the size, packaging & hazard communication conditions are authorized as excepted shipments when transported by highway. PRBA – seeking clarification if an “inner packaging” is required. DAMAGED, DEFECTIVE, OR RECALLED BATTERIES This provision authorizes the transport by highway, rail, or vessel “lithium cells or batteries that have been damaged or identified by the manufacturer as being defective for safety reasons, that have the potential of producing a dangerous evolution of heat, fire, or short circuit (e.g. those being returned to the manufacturer for safety reasons)” provided they are packaged in or accordance with the provisions listed below. 1. Each cell or battery must be placed in individual, non-metallic inner packaging that completely encloses the cell or battery; 2. The inner packaging must be surrounded by cushioning material that is noncombustible, non-conductive, and absorbent; and 3. Each inner packaging must be individually placed in one of the following Packing DISPOSAL OPTIONS: CALL2RECYCLE – - Rechargeable batteries only - Paid for by battery manufactures - www.call2recycle.org - Home Depot, Radio Shack, Staples, etc. THE BIG GREEN BOX – - All chemistries - Paid when boxes are purchased - www.bigreenbox.com PASSENGER PACKING FOR A PERSONAL TRIP Lithium & Lithium-ion batteries (spares) & small equipment (cameras) Are to be brought onto the passenger aircraft as CARRY-ON and not packed in CARGO. EXERCISE – NEED TO SHIP BACK TO HP 5 LAPTOP COMPUTERS RECEIVED WRONG MODEL – NOT DEFECTIVE Lithium Ion Battery 14.4 Volts 2450 mAh Computer – 5 lbs each LABEL/ MARK THE PACKAGE: Can it go by air?YES To: HP Returns From: Duracell Shipping Name:UN3481, Lithium-ion batteries contained in equipment, 9, PGII Doesn’t need to be spec packaging CT CONSUMER BATTERY STEWARDSHIP ACT HIGHLIGHTS • • 1st State in the nation to adopt a comprehensive battery recycling bill Both singe-use and rechargeable batteries Alkaline, zinc carbon, lithium, silver oxide, zinc air, rechargeable • NOT car batteries • • • • Retailers – drop off box or curbside recycling bin – being worked out Companies selling batteries must come up with a plan Behind the law: • Duracell, Energizer, Panasonic & Rechargeable Battery Association CT CONSUMER BATTERY STEWARDSHIP ACT HIGHLIGHTS • • • Primary or small rechargable battery Manufacturers – labeled clearly identify the type & chemistry of the battery Stewardship Plan 10% collection rate 2 years of program is implemented • 20% collection rate 5 years after program is implemented • • Free of charge to consumers • Both retail & bulk collection sites • • • Retail – no more than 100 batteries per visit Cost by manufacturers based on pounds Annual report – collection/sales/financial statement financing of the plan, collection points, educational materials, manner of sorting/recycling QUESTIONS?