Shipping Lithium Batteries by Ground
Introduction
Shipping lithium cells and batteries by ground is less restrictive than air and is the preferred method for transportation. Even though it is less restrictive, transporting lithium batteries by ground is still regulated and shippers must adhere to 49 CFR 173.185.
General Requirements
As the shipper it is your responsibility to ensure that all the requirements for shipping lithium batteries are met. If, for any reason, not all requirements are met, you should not offer the batteries for shipment.
When shipping lithium batteries or any devices containing lithium batteries, you must be aware that certain restrictions are in place to ensure safety during transport. Lithium batteries must:
- Meet the requirements of the UN Manual of Tests and Criteria, unless excepted
- Not be shipped if damaged, defective, or known to be unsafe
- Test summary must be made accessible
Since the risks posed by lithium batteries are unique and they do not meet the definition of any other hazard Class, they have been classified as a hazard Class 9 (Miscellaneous). Within Class 9 there are eight possible shipping names with corresponding ID numbers that can be used when shipping lithium batteries. The one you select should correspond with the type of lithium battery you are shipping as well as how the lithium batteries are packaged.
- UN3480 Lithium ion batteries
- UN3481 Lithium ion batteries packed with equipment
- UN3481 Lithium ion batteries contained in equipment
- UN3090 Lithium metal batteries
- UN3091 Lithium metal batteries packed with equipment
- UN3091 Lithium metal batteries contained in equipment
- UN3171 Battery-powered vehicle
- UN3536 Lithium batteries installed in cargo transport unit
UN3171 Battery-powered vehicle can only be used with vehicles that are solely powered by the lithium battery and do not have an internal combustion engine, such as a fully battery powered car.
Packaging
Packaging can make all the difference in the world. Lithium batteries that are properly packaged can prevent any unwanted damage or unnecessary incidents from occurring. Batteries that are improperly packaged can allow a battery to become damaged or allow it to short circuit. Always ensure your packaging meets or exceeds the regulation standards.
Requirements
Packages containing lithium cells or batteries must meet applicable requirements of Subpart B (Preparation of Hazardous Materials for Transportation) of Part 173. Lithium cells or batteries, including those packed with or contained in equipment, must also be packaged in a way that prevents:
- Short circuits
- Movement within the outer package
- Accidental activation of equipment
Lithium cells or batteries, including those packed with equipment, must be completely enclosed in a non-metallic inner packaging that separates the cells or batteries from contact with equipment, devices, or conductive materials such as metal. The inner package must then be placed in one of the following specification or UN rated outer package that meet Packing Group II requirements:
- Box made of metal (4A, 4B, 4N), wood (4C1, 4C2, 4D, 4F), fiberboard (4G), or solid plastic (4H1, 4H2)
- Drum made of metal (1A2, 1B2, 1N2), plywood (1D), fiberboard (1G), or plastic (1H2)
- Jerrican made of metal (3A2, 3B2) or plastic (3H2)
Lithium cells or batteries contained in equipment may not need additional outer packaging provided the equipment prevents the battery from short circuits, movement, accidental activation, and protection from damage. If these requirements are not met, the equipment must be placed in an outer package and packed to prevent movement and accidental activation of the equipment.
Batteries that weigh 26.5 pounds (12 kg) or more do not need to be packaged in a specification or UN rated package, provided the battery casing is strong and impact resistant. The battery must also be packed in a strong outer packaging; in a protective enclosure (for example, in fully enclosed or wooden slatted crate); or on a pallet or other handling device.
Anytime an inner package is placed inside an outer package, the inner package should be wrapped or separated from other inner packages or devices using one or a combination of the following:
- Foam wrap
- Bubble wrap
- Cardboard
- Styrofoam
Markings and Labeling
The marking requirements for fully regulated lithium cells or batteries are the same as other hazardous materials. The package should still be marked with the:
- ID number
- Proper shipping name
- Shipper’s or receiver’s name and address, when required
- Special permit number, when required
The labeling requirements for fully regulated lithium cells or batteries will change slightly compared to other hazardous materials. A Class 9 label would still be required on the package. However, you would need to use the Class 9 lithium battery label that has the battery image on it instead of using the normal Class 9 label.
Shipping Papers
Fully regulated lithium cells or batteries are required to have shipping papers. Other than what is normally required on a shipping paper, lithium cells or batteries do not require any additional information.
Exceptions
Not all lithium cells and batteries are fully regulated. In fact, most of the lithium cells or batteries that are shipped will be able to use the exceptions in 49 CFR 173.185(c). For the exceptions to be valid, you must follow all applicable requirements in 49 CFR 173.185(c). When using the exceptions, you do not need to:
- Use specification or UN rated packages
- Provide shipping papers
- Mark packages with a shipping name or ID number
- Apply the lithium battery Class 9 label to packages
- Provide emergency response information
- Comply with hazmat training requirements. However, you should be familiar with 173.185(c)
Even though you do not need to use specification or UN rated package, you must ensure the package is rigid and can withstand a 1.2-meter drop test. During the drop test, the contents of the package must remain inside the package, cells or batteries cannot be damaged, and cells or batteries cannot shift to a point that would allow battery-to-battery (or cell-to-cell) contact.
Size and Weight Limitations
To use the exceptions, there are size limitations that shippers must adhere to.
Lithium cells must not exceed:
Lithium Metal | 1 g |
Lithium Ion | 20 Wh |
Lithium batteries must not exceed:
Lithium Metal | 2 g |
Lithium Ion | 100 Wh |
Each package that contains lithium cells or batteries cannot exceed 66 pounds gross weight. This weight limitation does not apply to lithium cells or batteries contained in or packed with equipment.
Markings
Although proper shipping names and ID numbers are not required, the exceptions do require other markings to be displayed on the outer package.
Packages using the exception must have a lithium battery mark displayed. The mark must have the appropriate ID number displayed as well as a telephone number for additional information. The telephone number is different than the emergency response telephone number listed on shipping papers and does not need to be monitored 24/7.
The lithium battery mark does not need to be applied to a package containing:
- Button cell batteries installed in equipment (including circuit boards), or
- No more than four lithium cells or two lithium batteries contained in equipment, when there are no more than two packages in the consignment
A package that contains lithium cells or batteries must be appropriately marked with one of the following:
- PRIMARY LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT,
- LITHIUM METAL BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT,
- LITHIUM ION BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD PASSENGER AIRCRAFT, or
- Labeled with the CARGO AIRCRAFT ONLY label
The statements or CARGO AIRCRAFT ONLY label does not apply to packages containing lithium cells or batteries packed with or contained in equipment when the battery weighs 5 kg or less.
For highway and rail transportation, the size limitations may be increased to:
Lithium cells
Lithium Metal | 5 g |
Lithium Ion | 60 Wh |
Lithium batteries
Lithium Metal | 25 g |
Lithium Ion | 300 Wh |
Provided the package is marked with the statement "LITHIUM BATTERIES—FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL."