Transporting lithium batteries

Scope

The lithium battery requirements apply to shippers who offer lithium batteries for transportation, and to transporters that transport lithium batteries by air, highway, rail, or water.

Regulatory citations

• 49 CFR Parts 171-180 — Hazardous Materials Regulations (HMR)
• 49 CFR 173.185 — Lithium cells and batteries
• 49 CFR Parts 390-397
• International Air Transport Association (IATA) Dangerous Goods Regulations (DGR)

Key definitions

• Equipment: The device or apparatus for which the lithium cells or batteries will provide electrical power for its operation.
• Lithium cell(s) or battery(ies): The term lithium cell(s) or battery(ies) includes both lithium metal and lithium ion chemistries.
• Medical device means an instrument, apparatus, implement, machine, contrivance, implant, or in vitro reagent, including any component, part, or accessory thereof, which is intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, of a person.

Summary of requirements

Lithium batteries present both chemical and electrical hazards. They can be dangerous if not safely packaged and handled when transported. Misused, mishandled, improperly packaged, improperly stored, overcharged, or defective batteries can short circuit, overheat, cause a fire, or even explode.

Because of these hazards, lithium batteries are regulated as a hazardous material under the U.S. Department of Transportation's (DOT) Hazardous Materials Regulations (HMR). Lithium batteries must conform to all applicable HMR requirements when offered for transportation and when transported by air, highway, rail, or water.

It’s important to remember that ALL lithium cells and batteries are hazardous materials when being transported, no matter the size or quantity. However, there may be certain exceptions from the regulations depending on certain conditions and limits. It is the shipper’s responsibility to ensure that all the requirements for shipping lithium batteries are met. Requirements for shipping vary depending on whether you ship by ground or by air. If, for any reason, not all requirements are met, the batteries should not be offered for shipment.

Classification

Since the risks posed by lithium batteries are unique and they don’t 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. These descriptions, or proper shipping names, are found in the Hazardous Materials Table (HMT) in §172.101 of the HMR.

The shipping name selected should correspond with the type of lithium battery you are shipping as well as how the lithium batteries are packaged.

Packaging

Proper packaging can prevent unwanted damage or unnecessary incidents from occurring. Batteries that are improperly packaged can be damaged and could short circuit. Whether shipping by air or by ground, each package offered for transportation containing lithium cells or batteries (including lithium cells or batteries packed with, or contained in, equipment) must meet or exceed the regulation standards for packaging.

Marking and labeling

The package marking requirements for fully regulated lithium cells or batteries are the same as for other hazardous materials.

The Class 9 lithium battery label that has the battery image on it is required in place of the normal Class 9 label.

Packages containing lithium cells or batteries that are not allowed or forbidden for transport on passenger aircraft must have the “Cargo Aircraft Only” label applied.

Shipping papers

Fully regulated lithium cells or batteries must have shipping papers. Other than what is normally required on a shipping paper, lithium cells or batteries do not require any additional information when shipping by ground.

When shipping by air, IATA requires shippers to use the Shipper’s Declaration for Dangerous Goods form when shipping hazardous materials.

Shipping exceptions

When shipped by ground, 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 shipping by air, IATA DGR provides very few exceptions for lithium cells or batteries. Eligible cells or batteries that adhere to Packing Instructions 966, 967, 969, and 970 do not need to provide shipping papers.

Loading/unloading and segregation

The HMR contains requirements for the safe and secure loading and unloading of hazardous materials. A person who loads or unloads hazardous materials must comply with all the applicable loading, unloading, and segregation requirements in the regulations.

Placarding

Most packagings, freight containers, unit load devices, rail cars, and motor vehicles hauling hazardous materials must be placarded. However, for domestic transportation within the United States, placards are not required for Class 9 materials. Lithium batteries are Class 9 materials and therefore do not require placarding for domestic transportation in the United States.

Transport driver training

The driver of a motor vehicle transporting hazardous materials must receive training on the applicable requirements of the Hazardous Materials Regulations and the Federal Motor Carrier Safety Regulations.

This includes General Awareness/Familiarization, Function-specific, Safety, Security Awareness, and In-depth Security training. In addition, hazmat drivers must receive driver training on the safe operation of the motor vehicle that will be transporting hazardous materials.

A record of current training, inclusive of the preceding three years, must be created and retained by each hazmat employer for each hazmat employee for as long as that employee is employed by the employer as a hazmat employee and for 90 days thereafter.