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
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General Definitions
Battery
• Chemistry
• Lithium Metal
• Lithium-Ion
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DOT Definitions
Batteries
• Batteries With
Equipment
• Batteries In
Equipment
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• DOT
• Shipping Names
• Packaging
• Labeling
• Training
•Personal Travel
•Example
•CT Battery Recycling Laws
DEFINITIONS
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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
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Primary – used until “dead” and then discarded
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Alkaline
Zinc Air
Zinc Carbon
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Lithium Metal
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NiOOH
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Rechargeable – electrochemical reactions are electrically
reversible (use & recharge)
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Ni-Cad
NiMH
Lead Acid
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Lithium-Ion
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Fuel Cell
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LITHIUM METAL BATTERIES
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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
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What are Lithium-ion Batteries?
Thinner/flatter batteries
Rechargeable, multiple use
Cylindrical, pack or pouch batteries
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Pouch batteries
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MP3
Phones/pads
Non-removable battery
SHIPPING MODES
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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
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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
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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
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No more Equivalent lithium content conversion.
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Special Provisions 188 & 189 – deleted
173.185(c)
SPECIAL PROVISIONS, CON’T
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Special provision not listed in 172.101 table – most are
in the packaging requirements – similar to IATA &
IMDG
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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)
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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
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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
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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
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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
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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:
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No more than 2.5 kg lithium metal cells or 10 kg
lithium-ion cells
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Then not subject to UN performance packaging
requirements
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When Class 9 , Lithium battery handling Mark &
Cargo Aircraft Only Label
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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.
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PRBA – seeking clarification if an “inner packaging” is
required.
DAMAGED, DEFECTIVE, OR RECALLED BATTERIES
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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 –
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- Rechargeable batteries
only
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- Paid for by battery
manufactures
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- www.call2recycle.org
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- Home Depot, Radio
Shack, Staples,
etc.
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THE BIG GREEN BOX –
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- All chemistries
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- Paid when boxes are
purchased
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- www.bigreenbox.com
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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
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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
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Retailers – drop off box or curbside recycling bin –
being worked out
Companies selling batteries must come up with a plan
Behind the law:
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Duracell, Energizer, Panasonic & Rechargeable Battery
Association
CT CONSUMER BATTERY STEWARDSHIP ACT HIGHLIGHTS
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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
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Free of charge to consumers
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Both retail & bulk collection sites
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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?