Packaging and Shipping Batteries Safely

PRBA has developed this pamphlet to assist the U.S. battery and portable power industries in complying with applicable hazardous materials transportation regulations and to otherwise address concerns the U.S. Department of Transportation (DOT) has expressed about air transportation of battery and battery-powered equipment.

Introduction

What currently is required for shipments of batteries under the Federal hazardous materials transportation regulations? All batteries, alkaline, lithium, lead, nickel metal hydride, carbon zinc, etc., or battery powered products are subject to 49 CFR 173.21(c) in the U.S. hazardous materials regulations. This provision prohibits "the offering for transportation or transportation of ... electrical devices which are likely to create sparks or generate a dangerous quantity of heat, unless packaged in a matter which precludes such an occurrence." If a person offers batteries or battery powered products that do not comply with 49 CFR 173.21(c) they are in violation of the regulations and may be subject to civil penalties.

The Federal Aviation Administration (FAA) (a subagency of U.S. DOT) has issued three advisories relating to shipments by air of batteries and battery-powered equipment in the last five years. The U.S. DOT also wrote to PRBA and other concerned parties during the summer of 2004 urging that additional steps be takes to address the regulators' concerns. The U.S. DOT requested that the battery industry take the following additional safety precautions beyond those currently required in the Federal regulations:

• Separating a power source from the device while in transportation or providing an effective means to precent activation of the device;
• Providing "spark proof" covers for terminals; and
• Providing instructions to customers on the safety issues involved with batteries in transport.

Lithium and Lithium Ion Cells and Batteries

Lithium and lithium ion cells and batteries are listed as Class 9 Miscellaneous hazardous materials in the U.S. and international hazardous materials regulations and thus are subject to specific packaging, marking, labeling, and shipping paper requirements. In order to qualify for these exceptions, the batteries must meet certain testing requirements and/or contain a limited amount of lithium metal or "equivalent lithium content."

Regardless of whether a lithium or lithium ion cell or battery qualifies for the exceptions in the regulations, shippers must still comply with requirements of 49 CFR 173.21(c). That is, the cells and batteries must be securely packaged and offered for transportation in a manner that prevents the dangerous evolution of heat and short circuits.

The regulations that govern the transport of lithium and lithium ion cells and batteries recently were amended and can be very confusing. For example, the U.S. DOT published an Interim Final Rule in December 2004 that prohibits lithium primary battery shipments on passenger aircraft and requires new markings on all packaging containing lithium primary batteries. Therefore, prior to offering these cells and batteries for transport, these regulations should be carefully reviewed.

Lead Acid Batteries

Lead acid batteries are listed as Class 8 Corrosive hazardous materials in the U.S. and international hazardous materials regulations and also are subject to specific packaging, marking, labeling, and shipping paper requirements. However, like shippers of lithium and lithium ion cells and batteries, shippers of "nonspillable" lead acid batteries are provided an exception to the regulations if certain testing and marking requirements are met. These requirements include:

1. The battery must be protected against short circuits and securely packaged;
2. For batteries manufactured after September 30, 1995, the battery and outer packaging must be plainly and durably marked "NONSPILLABLE" or "NONSPILLABLE BATTERY";
3. The battery must be capable of withstanding the following two tests, without leakage of battery fluid from the battery:
   • Vibration test, and
   • Pressure differential rest; and
4. At a temperature of 55° C (131° F), the battery must not contain any unabsorbed free-flowing liquid, and must be designed so that electrolyte will not flow from a ruptured or cracked case.

Packages containing products with nonspillable lead acid batteries also must be marked "NONSPILLABLE" or "NONSPILLABLE BATTERY."

A nonspillable lead acid battery that does not meet the testing requirements noted above must be shipped as a Class 8 Corrosive hazardous material.

Dry Batteries

"Dry" batteries, such as alkaline, nickel metal hydride, nickel cadmium, and carbon zinc, generally are recognized as being excepted from the U.S. and international hazardous materials regulations provided they are packaged in a manner that prevents the generation of a dangerous quantity of heat and short circuits.

There is no official definition of what constitutes a "dry" battery. However, the U.S. DOT has issued numerous interpretation letters over the years that clearly recognize nickel metal hydride and nickel cadmium batteries as "dry" batteries. (See http://hazmat.dot.gov/regs/rules.htm.) Therefore, the overriding provisions that govern shipments of dry batteries are Special Provision 130 and 49 CFR 173.21(c) in the U.S. hazardous materials regulations. Any person that offers dry batteries or products containing dry batteries to a carrier that does not comply with Special Provisions 130 or 49 CFR 173.21(c) may be subject to civil penalties.

This document was developed for informational purposes only, and does not represent legal advice. PRBA expressly disclaims any liability, including but not limited to, consequential or other damages arising out the use of the information contained herein.

For more information on shipping batteries or PRBA, please visit www.prba.org or contact George Kerchner at (202) 719-4109.