April 2019

Do you understand the latest government regulations for transporting hazardous material and managing hazardous waste?   Contact me for further information .

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March 6, 2019: USDOT Changes Regulations for Transport of Lithium Batteries The interim final rule (IFR) issued by USDOT/PHMSA revises the Hazardous Materials Regulations (HMR) for lithium cells and batteries transported by aircraft. In this revision the USDOT/PHMSA harmonizes its HMR with the international regulations.  What are the key changes? The new ruling: Prohibits the transport of lithium ion cells and batteries when packed alone as cargo on passenger aircraft. Requires lithium ion cells and batteries to be shipped at not more than a 30% state of charge aboard cargo-only aircraft if not packed with or in the equipment it is meant to power (i.e. packed alone). Limits the use of the “small lithium cell or battery exception” for transport by aircraft at 49 CFR 173.185(c)(4) to one package per overpack or consignment. Allows for a limited exception from the above restrictions on air transportation for lithium cells or batteries in medical devices. My complete article identifies and explains this new USDOT/PHMSA regulation for the transport of lithium cells and batteries, including: Scope and applicability Passenger aircraft prohibition State of charge requirement Consignment and overpack restriction Limited exceptions to restrictions on air transportation of medical device cells or batteries Important note: Though mostly applicable to the transport of lithium batteries by air, this rule change also affects the transport lithium batteries by highway, rail, and vessel. Contact me for further information .

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What is the required size of the new Class 9 Lithium Battery label? Since January 1st of 2019, use of the Class 9 Lithium Battery label is mandatory for regulated shipments of lithium batteries. For highway or rail within the U.S - USDOT/PHMSA sets the minimize size to the four label sides to a minimum of 100 mm. However, t he label can be as small as necessary to fit on the package as long as it continues to communicate the necessary information. Or, as an option, a label may be displayed on a tag secured to the package. For vessels - The IMDG Code also sets a minimum size for the label on a package to a minimum of 100 mm on a side. However, the label may be smaller than this minimum if required by the size of the package. The shipper also has the option to display the label on a tag or by other means if the size of the package hinders display of a full-size label. For air - IATA Dangerous Goods Regulations establish a minimum dimension of 100 mm for each side of a label and DO NOT allow for the reduction in size of the hazard label except in very limited circumstances, and then, a reduction in size of no more than half of the minimum size.  For more specifics on the various regulations, read my blog article TIP : Though similar in many ways, there are significant differences between the regulations of USDOT/PHMSA, IMO, & IATA, even when dealing with something as seemingly insignificant as the display of a hazard label on a package.  Contact me to assist you with compliance.

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