DOT Lithium Battery Regulations to be Enforced Starting January 1st, 2008

On August 9th 2007, the Office of Hazardous Materials Safety, which is a part of the United States Department of Transportation?s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA), published their final ruling regarding the transportation and handling of lithium batteries. Their ruling follows closely to the UN Recommendations on the Transport of Dangerous Goods and Materials Regulations. These regulations have been put into effect as of January 1st, 2008.

What is the Ruling?

All lithium batteries and cells are to be grouped by their ?size?. The size of a battery is determined from the amount of lithium in the battery (see table below). Depending on the size classification of a battery, it has to adhere to a specific set of conditions when being transported.

	Small	Medium	Large
Primary Cells	Lithium content in cell must be less than 1 gram.	Lithium content in between 1 gram and 5 grams.	Lithium content of greater than 5 grams.
Primary Batteries	Lithium content must be less than 2 grams.	Lithium content in between 2 grams and 25 grams.	Lithium content of greater than 25 grams.
Secondary Cells	Equivalent Lithium Content (ELC) of less than 1.5 grams.	ELC in between 1.5 grams and 5 grams.	ELC of greater than 5 grams.
Secondary Batteries	ELC of less than 8 grams.	ELC in between 8 grams and 25 grams.	ELC of greater than 25 grams.

The equivalent lithium content (ELC) of a battery is a function of the number of cells in the battery and the rated capacity of the battery in ampere-hours.

ELC = 0.3 * (# of Cells) * (Capacity (in ampere-hours))

Small lithium cells or batteries can be transported as a non-restricted material by any means of transportation provided they successfully complete the UN ST/SG/AC.10/aa/Rev. 4 Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria ?T1-T8? tests (altitude simulation, thermal test, vibration, shock, external short circuit, impact, overcharge, forced discharge). This part of the ruling will not be enforced until October 1st, 2009. However, it is strongly recommended that these tests be run on lithium batteries of all sizes to avoid accidents during shipments.

Medium lithium cells or batteries need to successfully complete the UN?s T1-T8 tests before they can be transported by any means. If they pass these tests, they can be transported as a non-restricted material by rail car or highway only. In order to ship by air, they have to pass the UN?s tests and also be classified as a Class 9 Hazardous Material.

Large lithium cells or batteries need to be classified as a Class 9 Hazardous Material and pass the UN?s T1-T8 tests to be shipped by any means of transportation. All untested batteries may be shipped to a test facility by highway only, and need to be classified as a Class 9 Hazardous Material.

How often does a battery need to be tested?

The UN T1-T8 tests need to be run at least once, for every battery or cell design. The ruling states a cell or battery that differs from a tested type by:

A change of more that 0.1g or 20% by mass to the cathode, anode, or the electrolyte,

OR

A change that would materially affect the results,

shall be subjected to the required tests. Even if a battery is made from cells that have previously successfully completed the UN tests, it is required to pass the tests again.

What happens if the ruling is not complied with?

If the DOT audits you and finds out that the rulings are not being complied with, fines of up to $100,000 dollars can be assessed per infraction. With these new rulings recently put into effect, it is expected that the DOT will be actively enforcing these requirements. The only way to ensure that you are complying with the rulings is to have your product tested. The associates at MGA have been testing batteries for over 25 years, and are leading the way in complying with the new lithium transportation standards. We are recognized by the DOT as being fully capable to test lithium batteries to the UN standards.

Please do not find yourself on the wrong side of a DOT audit! Contact Suzanne Phillips (suzanne.phillips@mgaresearch.com) at +1-877-Z-TESTNOW find out how we can help you meet your needs. If you would like to learn more about the shipping regulations imposed by the DOT, visit their website at (http://hazmat.dot.gov/regs/rules/final/72fr/docs/72fr-44929.pdf).
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