Battery Power - May/June 2013 - (Page 6)

Feature Shippers of Lithium Batteries and Equipment Experience Delays as New Air Transport Requirements Take Effect Bob Richard, Vice President of Regulatory Affairs Labelmaster Services Newly enacted regulations for transporting lithium batteries and lithium battery-powered equipment are causing various holdups due to a lack of awareness among some shipping and transport personnel. New requirements for shipping lithium batteries and lithium battery-powered equipment under the new 2013-2014 International Civil Aviation Organization’s Technical Instructions on the Safe Transport of Dangerous Goods (ICAO TI) came into force on January 1st, 2013. In the US, the HM-215L final rule published on January 7th authorized the use of the 2013-2014 ICAO TI. According to several customers and clients, these new rules are already causing some headaches among shippers and carriers, which may not be all that surprising considering the narrow window between the adoption of the revised lithium battery packing instructions and the publication of the ICAO TI coupled with the lack of a transition period for compliance with new requirements (a common practice of the ICAO Dangerous Goods Panel). Unless one follows the work of the ICAO DGP and maintains an awareness of pending changes to dangerous goods regulations, they might not be aware of the changes until they receive their 2013-2014 copy of the ICAO TI or the 2013 A.I.R. Shipper. These latest regulation changes were adopted by the ICAO DGP in February 2012 and the report highlighting the agreedupon modifications was not available until March 2012. The ICAO TI was published in late fall of 2012, leaving a limited amount of time for companies to examine the impact. It is certainly a challenge for many companies to assess these changes, as they may have to: • Review operations and impacts to current procedures; • Develop or update training programs; • Implement training to, in some cases, thousands of employees; and • Revise procedures and operations including revising internal documentation, standard operation procedures, battery documents and package markings. The newest changes presented particular challenges because many companies that previously shipped lithium batteries and equipment under the previous exceptions have now been swept up into the community of dangerous goods shippers. Companies that ship limited items (e.g. laptops and smart phones for field staff) have found themselves having to revise operations and 6 Battery Power • May/June 2013 train a significant numbers of employees. Many retail and online distributors are extremely challenged by the new requirements. As a past regulator, I admit that I have a better understanding and appreciation for what companies have to go through to ensure their operations are compliant now that I am working at Labelmaster Services to support companies with their compliance challenges. While the ICAO DGP did not provide an official transition period, it did recommend that competent authorities provide a 30day grace period. It is not entirely clear whether the intent was to allow goods in the supply chain to get through to the destination or to allow shippers a month longer to comply. However, Dave Brennan, the International Air Transport Association’s assistant director of Cargo Safety & Standards, recently clarified that the transition was exactly to provide an additional month to comply. “Shipments presented for air transport by 31st December can always move to destination in the new year regardless of how long that takes,” Brennan said. “Second, there is one very important difference between air and the other modes. No other mode has a mandatory acceptance check by the operator. That makes a transition period very difficult for the operators.” Given that this was a recommendation and not a requirement, shippers were left wondering which competent authorities recognized the grace period and who did not observe it. On the basis of this experience one must wonder whether the dangerous goods air shipping community should ask the ICAO DGP to consider authorizing reasonable transition periods. Wouldn’t it be simpler if all of the modal bodies had consistent transition periods? The transition has come and gone so it really doesn’t matter at this point, but hopefully lessons can be learned for future transition considerations. What Problems are Lithium Battery Shippers Experiencing? The revised definition of the terms “Battery” and “Cell” are causing some shipments to be frustrated. According to some of our customers and clients, shippers are finding that some airline and freight forwarder personnel are either not aware or not properly interpreting the latest definition of lithium cell and battery. In addition, it is common practice for a single cell battery to be referred to as a battery on invoices, packing slips and correspondence. The definitions for batteries and cells changed recently in the UN Manual of Tests and Criteria 5th Revision, Amendment 1, which is referenced in the ICAO Technical Instructions. According to the UN Manual of Tests and Criteria, 5th Revision, Amendment 1: Battery means two or more cells that are electrically connected together by permanent means, including case, terminals and markings. A single cell battery is considered a “cell”. Cell means a single encased electrochemical unit (one positive www.BatteryPowerOnline.com http://www.BatteryPowerOnline.com

Table of Contents for the Digital Edition of Battery Power - May/June 2013

Polaris Battery Labs and Carestream Tollcoating Form Alliance
Intelligent Enumerating Battery Charger Provides Safe and Fast Charge for Mobile Equipment
Shippers of Lithium Batteries and Equipment Experience Delays as New Air Transport Requirements Take Effect
A New Method for Maintaining the Charge of VRLA Batteries in Telecommunications Standby Systems
Battery Power 2013 Conference Preview
Batteries
ICs & Semiconductors
Charging & Testing
Components & Materials
Industry News
Research & Development
Marketplace

Battery Power - May/June 2013