Lithium batteries pose a fire hazard, even when they are no longer useful in consumer equipment/products. Damaged, defective, or recalled batteries have greater potential than undamaged lithium batteries to short circuit, to release heat, or even to cause a fire. Anyone who offers a used lithium battery for disposal or recycling must, in addition to ensuring the terminals are protected to prevent short circuiting, fully assess the potential for fire hazards in shipping.
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The Safety Advisory Notice discusses the essential requirements for preparing packages of used batteries for disposal or recycling and highlights additional resources for further information.
The Safety Advisory Notice can be viewed in its entirety at: https://www.phmsa.dot.gov/training/hazmat/safety-advisory-notice-transportation-lithium-batteries-disposal-or-recycling.
Additional DOT Resources for Recyclers/Collection Operators/Transporters:
Lithium Battery Guide for Shippers
Sustainable Materials Management (SMM) Web Academy Webinar &#; Safe Transportation of Lithium Batteries: What You Need to Know in
OSHA Information
The Occupational Safety and Health Administration (OSHA) maintains a website dedicated to battery disposal resources: https://www.osha.gov/green-jobs/recycling/batteries
EPA Information
Environmental Protection Agency (EPA) regulations apply to end-of-life lithium ion batteries under the Resource Conservation and Recovery Act (RCRA). In May , EPA issued a memo to clarify how the hazardous waste regulations for universal waste and recycling apply to lithium ion batteries: https://rcrapublic.epa.gov/rcraonline/details.xhtml?rcra=. In addition, EPA maintains a website dedicated to battery disposal resources: https://www.epa.gov/recycle/used-lithium-ion-batteries, as well as a list of frequently asked questions for household batteries: https://www.epa.gov/recycle/used-household-batteries.
Private Individuals and Households
Private individuals should dispose of household lithium batteries via appropriate recycling channels and should never place lithium batteries in the trash or general recycling due to safety concerns. Electronics recyclers or scrap/collection centers in your area can be found online. Certain grocery, home improvement, big box retail, and consumer electronics stores offer lithium battery recycling services. In addition, your local solid waste district may offer a lithium battery collection program or host regular collection events. The manufacturer of your electronic may also offer a mail-in program. Should you utilize a mail-in program, you must comply with all USPS (for USPS mail shipments) or DOT (for shipments with other carriers) requirements. The organizer of your mail-in program should provide you with the guidelines to ship in compliance with USPS and/or DOT requirements.
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You can refer to the EPA's webpage dedicated to household batteries for more information and for tips on locating appropriate recycling channels in your area: https://www.epa.gov/recycle/used-household-batteries
Our recent webinar, "Charging Ahead - Lithium Battery Requirements in and Beyond," garnered an overwhelmingly positive response, and if you missed it, don't worry &#; you can catch up on demand. The insightful discussions delved into crucial topics shaping the landscape of lithium battery transportation and usage. Here's a summary of the key highlights:
ICAO State of Charge Restrictions for Air Transport:
Back in the International Civil Aviation Organization (ICAO) set a 30% state of charge (SOC) limits on air shipments of standalone lithium-ion batteries. Recently, ICAO took a decision to extend that 30% SOC restriction to air shipments of lithium ion batteries packed with equipment. This SOC limit will become effective January 1, , but it is recommended that these batteries are held to a SOC not exceeding 30% of their rated capacity beginning January 1, . Further, ICAO is adding a recommendation that all lithium ion batteries contained in equipment shipped by air be at a SOC of 30% or less. These decisions have significant implications for the supply chain of lithium batteries and battery-powered devices.
UN TDG WG on Lithium Battery Classification:
The UN Working Group on Lithium Battery Classification is continuing its work to identify the hazards of lithium cells and batteries during thermal runaway and classify them accordingly. While the project is far from finalized, there have been discussions on adding many new UN numbers, test protocols, and how SOC and packaging may affect classification. The ultimate goal is to establish hazard-based classifications and incentivize safer cells and batteries.
SAE G-27 Lithium Battery Packaging Standard:
Established by ICAO in , the SAE G-27 committee is working on a package performance standard for the safe air transport of lithium cells and batteries. Focused on cylindrical cells like s and s, the standard includes rigorous test procedures to ensure safety during transport. However, challenges, open issues, and test validation raise questions about its implementation timeline and regulatory use.
New Battery Technology and Chemistry: Sodium Ion Batteries
With the electrification of nearly everything, the battery industry is always on the lookout for new battery chemistries. One such chemistry, sodium-ion batteries, has recently been introduced into the dangerous goods regulations with the creation of new UN numbers. For now, the shipping requirements for sodium ion batteries will mirror the lithium-ion rules.
Popular Questions and Answers:
The webinar generated a burst of questions from participants, ranging from the application of regulations to specific scenarios like reverse logistics and consumer electronics. Notable queries included concerns about the SOC limit for medical equipment, the impact on commercial aircraft restrictions, and the potential distinction between lithium-ion and LiFePO4 batteries. Here are some of the ones we would like to emphasize or that we didn&#;t have time to address during the discussion:
Will the 30% SOC for shipping apply to medical equipment?
Yes. While regulators are aware of concerns regarding the urgent need to ship fully charged medical devices and their batteries, there are no specific regulatory carveouts for medical devices at this time.
Batteries packed with or contained in are delivered to a distributer by ground where SOC does not apply, but then the distributor will ship the product by air to customers. How will the distributer know what the SOC is for these products when they are in final packaging?
It is the shipper&#;s responsibility to comply with shipping regulations, including any SOC limits. Controlling SOC on customer returns will be extremely challenging, which is why ground/ocean shipping would be recommended in these instances.
I checked the ICAO website and couldn't find anything about SOC changes to WITH at this time. Do you have a link to share?
Yes, you may visit - (AC.10/C.3) ECOSOC Sub-Committee of Experts on the Transport of Dangerous Goods (sixty-third session) | UNECE for more information.
Are Lithium Iron Phosphate batteries treated the same as lithium-Ion batteries?
Yes. Lithium iron phosphate batteries are a type of &#;lithium ion&#; chemistry.
Conclusion:
As the regulatory landscape for lithium batteries evolves, staying informed and actively participating in discussions is crucial for businesses and professionals in the industry. The "Charging Ahead" webinar provided valuable insights, and the diverse range of questions posed by participants reflects the complexity and depth of these evolving regulations. As we look to the future, it's clear that continuous dialogue and collaboration will be key in navigating the dynamic challenges of lithium battery transportation and ensuring the highest standards of safety and compliance. CHEMTREC will seek to provide more webinars like this in , stay tuned!
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