Lithium Batteries Shipping Rules Discussions

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Lithium Batteries Shipping Rules Discussions

Post by RLT » Sat Sep 13, 2008 1:28 am

I just thought it might be a good idea to expand on Jimmyg's post over in the e-bike general discussion forum.
viewtopic.php?f=3&t=6411

Jimmy has apparently been royally screwed by UPS, due to government bureaucrats making decisions without full information, and it looks like to me, this is going to effect ALL of us USA based EV people in a very negative way.(and a lot of regular folks too.)

This is from the UPS website: http://www.ups.com/content/us/en/about/ ... ttery.html
Lithium Battery Regulation Change
Service Update

Effective October 1, 2008, medium lithium batteries become fully regulated for air shipment in the U.S. Department of Transportation's (DOT) Hazardous Materials Regulations. Lithium batteries are considered a hazardous material because they can overheat and ignite in certain conditions and, once ignited, can be especially difficult to extinguish.

The new regulation will require packages containing medium lithium batteries, and offered for air transport, to be properly packaged, marked, and labeled as Hazardous Materials and accompanied by shipping papers. Otherwise, the shipment may be delayed, or significant U.S. DOT fines could apply. U.S. DOT has the ability to issue fines and penalties as high as $50,000 per violation for non-compliance.

Common examples of medium lithium batteries include:

* Power supplies for high-intensity, long-life portable lighting, such as diving lamps
* Some extended-life batteries for laptops
* Larger batteries for high-level video cameras (used by film and news crews)
* Long-life communications power supplies


These changes apply to shipments of loose medium lithium batteries as well as medium batteries contained inside of equipment, or packed with equipment.

Beginning October 1, 2008:

* Air shipments of medium lithium batteries must display the "Cargo Aircraft Only" label if the package exceeds 5 kg (11 pounds). UPS accepts hazardous materials only from shippers with a contract or agreement for such service.

* Ground shipments of medium lithium batteries must be marked as follows:

o "LITHIUM BATTERIES - FORBIDDEN FOR TRANSPORT ABOARD AIRCRAFT AND VESSEL."

o Text size for the above marking depends on the size of the package:
+ Gross weight of 30 kg (66 LB) or less - letters at least 6 mm (0.25 inch) high
+ Gross weight over 30 kg (66 LB) - letters at least 12 mm (0.5 inch) high

o If there are more than 12 batteries in a package, DOT requires an additional damage warning both on the package and in an accompanying document that would be affixed to the package in a resealable envelope. The DOT-required warning and document both advise handlers that the package contains lithium batteries and that certain safety measures are required if it is damaged.

For full information about these changes, shippers should review the applicable U.S. DOT Final Rule. Shippers may also contact the U.S. DOT Pipeline and Hazardous Materials Safety Administration's Hazmat Info-Line at 1-800-467-4922.


I hope I'm just not understanding the regulation properly and overreacting, but I see this as a very bad situation with far-reaching consequences.

Someone at least needs to educate these bureaucrats about the safety and stability of LiFe batteries, at least.
Last edited by amberwolf on Sun Feb 02, 2014 12:35 pm, edited 1 time in total.
Reason: edited title for merged threads

nutsandvolts

Re: New DOT rules on shipping lithium batteries in US

Post by nutsandvolts » Sat Sep 13, 2008 2:43 am

.
Last edited by nutsandvolts on Sat Oct 17, 2009 4:48 am, edited 1 time in total.

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Re: New DOT rules on shipping lithium batteries in US

Post by TylerDurden » Sat Sep 13, 2008 7:19 am

I'll be comforted to know that I'm safe from clipper-wielding terrorists... as my aircraft freefalls.

Less spare fuel can mean 'nightmare' flight
By Thomas Frank, USA TODAY

Rich Szulewski was in an airplane circling above Memphis International Airport late on April 10 when the captain delivered annoying news: The plane was running low on fuel and had to land in Little Rock to get more before going to Memphis. By the time the plane got to Little Rock, the pilots had spent so much time flying that flight rules barred them from continuing until the morning. Szulewski had been through enough. He rented a car, drove two hours to Memphis and got home at 3:30 a.m.

"It was a nightmare," Szulewski said.

Hundreds of thousands of passengers a year endure late arrivals, missed connections and hours of waiting when their flights are diverted to another airport.

Many factors cause diversions. Bad weather prevents landing at a destination. Mechanical problems force pilots to a nearby airport. And planes running low on fuel cannot circle above an airport waiting for weather to pass or congestion to clear.

Some pilots say they are making many fuel stops.

In a December report filed with NASA, an airline captain said he had diverted several flights in recent months because his plane was not given enough fuel to withstand delays. The captain, whose name and airline are not disclosed in the report, blamed the December diversion on "unrealistic fueling policy of my (airline). It is not consistent with the realities of the perpetually congested airspace system."

"Decisions and policies on aircraft fuel loads," the captain added, "are based on the economics of the industry, not the realities of the antiquated (air-traffic control) system that demands more fuel as a result of the airspace saturation causing extensive holds."

Diverting to refuel can unnerve passengers such as Melanie Marken, whose Pittsburgh-to-Denver flight in June was forced to stop in Cheyenne, Wyo. "It's a little disconcerting to hear the pilot say we don't have enough fuel to be in a holding pattern," Marken said.

Pilots and airlines say planes always have enough fuel to get to a destination and circle for 45 minutes, as the FAA requires. "I don't think it's a safety issue. It's more of a convenience issue," said Karl Schricker of the Allied Pilots Association, the union representing American Airlines pilots.

Dispatcher Ted Christie said flight captains must approve a fuel plan that dispatchers develop based on factors such as flight distance, airplane weight, weather and expected delays. "If the captain doesn't agree, the airplane doesn't go," said Christie, vice president of the Airline Dispatchers Federation.

But several captains wrote in NASA reports that dispatchers had "challenged" their requests for more fuel.

Christie said airlines "have put more emphasis to us on fuel conservation." He has cut from an hour to a half-hour the amount of "hold" fuel he puts on flights going to congested airports because he's realized planes seldom circle above an airport for an hour. "We're certainly encouraged to no longer put an hour of hold fuel every day," Christie said.

Capt. Mary McMillan of the Air Line Pilots Association praised steps to reduce fuel loads as soaring oil costs have pushed airlines into bankruptcy. "It used to be we really didn't think twice about fuel. We just said fill 'er up," McMillan said. "There's much more emphasis on flying efficiently."

Flights are landing with less left-over fuel than before, which is "driving down that comfort level" for some pilots, McMillan said. "You're re-establishing the comfort zone, and it doesn't happen overnight."

Airlines have always tried to conserve fuel, but when oil cost $20 a barrel, carrying a lot of spare fuel "was not enough to impact the bottom line," said David Castelveter of the Air Transport Association, an industry trade group. With oil now at $125 a barrel, "carriers are trying to reduce the weight on board the airplane," Castelveter added. When pilots want more fuel than dispatchers allocate, "the carrier is saying, please let me know why, because that's extra weight."


http://www.usatoday.com/travel/flights/ ... avel_N.htm
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Re: New DOT rules on shipping lithium batteries in US

Post by Link » Sat Sep 13, 2008 2:04 pm

nutsandvolts wrote:It sounds like just a bit more red tape.


It also sounds like the potential for extra shipping costs. :? I'm with RLT: Someone seriously needs to get a clue about the differences between LiPo/Co and everything else.
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Re: New DOT rules on shipping lithium batteries in US

Post by swbluto » Sat Sep 13, 2008 6:58 pm

Link wrote:
nutsandvolts wrote:It sounds like just a bit more red tape.


It also sounds like the potential for extra shipping costs. :?


Yep. Regulation = More (time+money) = more costly

Let's just hope the only thing affected is the declarations procedure and not the "cheapest route" possibility and shipping expenses. So, only time would be affected, and it'll be the filling-out-the-documents time of the seller. :wink:
Last edited by swbluto on Sun Sep 14, 2008 2:14 pm, edited 1 time in total.

nutsandvolts

Re: New DOT rules on shipping lithium batteries in US

Post by nutsandvolts » Sun Sep 14, 2008 1:25 am

.
Last edited by nutsandvolts on Sat Oct 17, 2009 4:48 am, edited 1 time in total.

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Re: New DOT rules on shipping lithium batteries in US

Post by swbluto » Sun Sep 14, 2008 1:58 am

nutsandvolts wrote:
TylerDurden wrote:The plane was running low on fuel


These guys completely ran out of fuel in a 767. I was living in that area at the time, I recall watching a documentary about this:

"In effect, the highly advanced flying machine had roughly the maneuverability of a flying brick, with barely enough instrumentation to monitor its slow dive towards the Earth."

"had determined the fuel weight by multiplying the the number of dripsticked liters by 1.77, as indicated by the documentation. However, unbeknownst to the pilots and the fuel crew, this multiplier provided the weight in imperial pounds; the new, all-metric 767 was based on kilograms, and required a multiplier of 0.8. As a consequence of this documentation disconnect, Flight 143 had left Montreal with roughly half the necessary fuel."

Canada was not metric when I was young, metric is like a second language to me, and apparently others :shock:

http://www.damninteresting.com/?p=744


It seems these conflicting unit-systems are a major focal point of systems failure by the computer controller. I don't remember the space ship, but something dreadful happened due to someone mistaking metric for imperial units, or vice-versa, in the space ship's controller.

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Re: New DOT rules on shipping lithium batteries in US

Post by marvingalaxy » Mon Sep 15, 2008 7:11 am

I just read all 22 pages of the new regulations. As far as I can tell, as long as the package is under 30kilos and is labeled correctly and packaged so that the battery is insulated and can withstand a 1.2m drop test that it is still acceptable to ship lithium batteries. I know, LiFePO4 is not the same as LIPO or what they call lithium "primary" batteries (not rechargeable) but the regulation is for all lithium batteries.

UPS is requiring all shippers of lithium batteries to get permission in their contract to ship lithium batteries and labels and a hazmat manifest is now required. There may be an exception for batteries under 5kilos but that certainly won't pertain to my pack.

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Lithium battery shipping resolved yet?

Post by marvingalaxy » Wed Oct 08, 2008 10:37 pm

Have the Lithium battery suppliers (notably Ping) figured out how to ship batteries with the new regulations that started October first? I know that UPS destroyed someone's pack a few weeks ago ahead of the new rules and I don't want that to happen with a $1000 battery pack. Has anyone ordered a Ping battery that arrived after the beginning of the month?

I know that LiFePO4 packs aren't the kind that the legislation was intended, but UPS have already been totally out of line with them and I don't want to live that myself. If my pack was intercepted and destroyed I wouldn't be able to afford another for quite some time and would have to resort to a pack with less range than would be completely practical for my needs. I would quickly go from electric cruising to hill-assist only which would be a shame with an X5304.

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Re: Lithium battery shipping resolved yet?

Post by marvingalaxy » Sat Oct 11, 2008 1:09 am

I'm a little surprised that nobody knows if batteries are being shipped from China. This seems like a critical issue for people like me that aren't capable of putting together their own packs from loose cells.

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Re: Lithium battery shipping resolved yet?

Post by marvingalaxy » Sat Oct 11, 2008 4:52 am

viewtopic.php?f=3&t=6834&st=0&sk=t&sd=a&start=15#p103867

"I did consider getting a Ping batt. as he gave me a very reasonable quote, but he was having shipping issues recently and I felt more confident about the folks at ebikes.ca."

Ping has already lost a sale due to the shipping problems and I am holding back. Fortunately, the sale went to another trusted seller who supports ES but knocking out the only source of pre-made ebike LiFePO4 packs under $1000 (for practical size packs) is a huge blow to our interest.

I'll stop bumping this thread, but I must throw in that I am surprised nobody is talking about this issue. If you are buying a Ping pack or ordering more than a couple of tool packs and using air freight you are effected by this new rule.

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Re: Lithium battery shipping resolved yet?

Post by nicobie » Sat Oct 11, 2008 12:53 pm

Maybe somebody should start a thread asking, "Anyone received a Ping battery pack since Oct. 1?"

I'm also ready to order but won't until this gets sorted out.

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Re: Lithium battery shipping resolved yet?

Post by StevenR » Sat Oct 11, 2008 9:45 pm

I'm going to order another Ping Pack (split to fit in panniers and run in parallel with my other pack on a 5303) and got this response from Li Ping:

The government hasn’t removed the shipping restrictions. But now the agent of EMS is able to help us ship batteries through EMS. However, there's about 10% possibility it could be rejected by the airport. But it can be resent but will take 3 or 4 more days. After all, it's almost impossible to be rejected for 2 times.

That doesn't relate to the UPS/Air Freight issue but it sounds like that isn't a problem unless it's a big shipment of batteries.

I'll probably get the pack on order tomorrow and report back it there are any problems.
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Appears to Be! Re: Lithium battery shipping resolved yet?

Post by AndyH » Sun Oct 26, 2008 6:02 pm

I got a 'care package' from Taiwan on Oct 21st - three boxes, 51Kg, that included 98 LiFePO4 40138 cells - via UPS.

I can't speak for any other shippers, but PSI is shipping!

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Re: Lithium battery shipping resolved yet?

Post by docnjoj » Tue Oct 28, 2008 3:00 pm

I just got another "winner" from the Pingster! 48 volts 20 AH per Dogmans recommendation (bigger really is better :) ) and it arrived within a week from Xanghai thru EMS and USPS! No hazardous labels I could spot, very well wrapped and usual quality. 60 volt charger has a teeny little fan that sounds like a WW2 air raid siren, but seems to work fine at 60.5 volts output. The pack quite big, but my trike has loads of room so tomorrow will be tentative test day! Cant wait to actually have enough power finally. I know, there can never be" enough" but this should allow commutes of 20+miles or so. The $200 cash back from Microsoft was the deal maker, even though I would have bought it eventually anyway. My wife has had zero trouble from her 36 volt Ping in the year she has had it , maybe 230-250 cycles.
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Re: Lithium battery shipping resolved yet?

Post by Doctorbass » Tue Oct 28, 2008 9:35 pm

On every battery i send, I indicate: Electronic components and i just avoid writing LITHIUM battery

I never had any bad feedback from a buyers. and... I still use Canadapost.

Konions are also in the kind of SAFE lithium battery like the A123.. but i dont know if any shipper pay attention to that... Also.. they could never know it's Konions battery in the same very similar 18650 shape like Li-Cobalt battery :roll:

Anyway.. I ship them in their original cordless tool plastic pack! that are built to endure hard environment.. so i guess they dont bother with that.. :?

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Re: Lithium battery shipping resolved yet?

Post by nicobie » Mon Nov 03, 2008 1:07 pm

I just received an excellent battery from Mr. Ping. Total shipping time was 3 days from China to the west coast of the US. I don't know how he does it. Shipped on the 30th and got it Sat. the 1st. EMS and USPS were the carriers.

On the shipping label nothing was mentioned about it being a battery. In fact the area on the form where the description goes was left blank :lol: . It might have helped that the return address was, "Xu-Guang Precision Mold Co." and that he had a Customer code.

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Re: Lithium battery shipping resolved yet?

Post by ping » Tue Nov 11, 2008 7:01 pm

Yes, resolved. Now we ship batteries with EMS.

UPS really sucks. There must be a guy or a team in KY who don't know anything about Lithium batteries and don't want to know, although we did provide all information. They held many packages to east coast and we had to full refund to those customers.

Fortunately, it's over now.

We have been emailing customers who were waiting for EMS shipping one by one but haven't finished contacting all of them so far.

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Shipping of Lithium batteries

Post by michaelplogue » Sun May 10, 2009 3:21 am

So, with the restrictions by UPS/FEDEX/USPS and IATA (International Air Transport Association) on the shipment of all lithium batteries, has anyone had any problems getting theirs mailed to them?

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Re: Shipping of Lithium batteries

Post by BMI » Sun May 10, 2009 7:11 am

Michael shipping restrictions only apply to the hazardous chemistry lithium ion batteries (for good reason). These restrictions don't apply to the shipping of LiFePO4 batteries so long as the MSDS accompanies the shipment. LiFePO4 batteries from approved suppliers are exempt with regard to the transpart regulations imposed by IATA.
You would know this from the BMI cells I shipped you from the factory for your e-knock electric motorcycle project. All the appropriate shipping documents were sent with the cells which is why there was no problem shipping the cells to you by airfreight.

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Re: Shipping of Lithium batteries

Post by AndyH » Tue May 12, 2009 4:36 pm

michaelplogue wrote:So, with the restrictions by UPS/FEDEX/USPS and IATA (International Air Transport Association) on the shipment of all lithium batteries, has anyone had any problems getting theirs mailed to them?


All of mine are coming in air-mail - no trouble at all.

It appears that shipping restrictions actually decreased. Here's a look at the suggested changesprocess from the Dangerous Goods Panel of the International Civil Aviation Organization.

ICAO DGP Comment Para 1.3 wrote:In light of the number of incidents involving lithium metal and lithium ion batteries, it is felt that the quasi-regulatory treatment of these batteries is not justified. The batteries should be shipped fully in accordance with the provisions of the Technical Instructions, including marking, labelling, testing, packaging standards, and pilot notification.


According to the wording in Special Provision A45, no marking is required if fewer than 24 lithium cells or 12 lithium batteries are shipped in a container weighing less than 30 kilos.

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Fines up to $50,000 for shipping lithium ion batteries!

Post by E-BikeKit.com » Sat Jun 27, 2009 9:09 am

Taken from an email from Dr. Morgan Giddings, CTO, Cycle 9, LLC

Dear electric vehicle sellers and enthusiasts:

The US Department of Transportation can levy fines up to $50,000 fine per infraction for shipping any type of lithium ion battery, which includes LiFePO4, without packaging it and marking it as "class 9 hazardous material," and having the full UN testing regimen for each and every battery pack type you sell (which is a destructive test of at least 5-10 complete battery packs of each type). Each of your employees shipping such batteries must be trained and certified as hazardous materials shippers. If an end-user of a lithium pack ever has problems with it and needs to send it back, they will be in non-compliance with this law, and could also be fined $50k per infraction.

Folks, this is no joke. At least one person I know has already encountered this issue, with fines yet to be determined.

The DOT are serious about enforcing it. It seems to apply to road, air, and public waterway transportation in the US. All rechargeable lithium ion batteries with above 25g (that's grams) of lithium are classified this way. That threshold is the equivalent of a 24 volt 10 amp hour pack. If you ship any type of lithium battery in quantities larger than that, this DOT rule applies to you (and me). Smaller batteries can be excepted in some circumstances, but few e-bike or EV batteries are smaller than that.

See the message below that I received today from George Kirshner of the "portable battery manufacturer's association." In that message he goes so far as to suggest that people could make anonymous tips about people shipping li-ion batteries in non-compliance. He makes no distinction among battery types, he and his organization, in dealing with DOT, treat all li-ion batteries the same. There is no exception for electric vehicles, or LiFePO4.

Most importantly, they do not acknowledge the inherent safety differences between a chemistry like LiCoO2 (which I would never put on my bike) versus LiFePO4 (which I gladly use on my bike). In my own experience, we've had more concerns over problems with NiCd and NiMH packs, than with LiFePO4. Yet for the purposes of DOT, LiFePO4 is a Class 9 Hazardous material, whereas the Nickel batteries are not. I think this is because people like George represent laptop and cell phone manufacturers, and those are the folks who have the clout (so far) with the DOT. They mostly deal with LiCoO2 because of its higher energy density (but also worse safety). The needs of a laptop or cell phone are quite different than an EV or LEV. We need to get the DOT on the right page here.

Some of you may think that it is easy to slip under the radar. But if there is ever an incident involving one of your batteries, the fines can increase to $100k per infraction (and they can charge for multiple infractions per incident). It is real.

And it gets worse.

Today, i realized that all of us who use a light electric vehicle with lithium batteries are carrying those batteries on public roads. That means we fall under the auspices of DOT. Technically, we are each therefore transporting "Class 9 hazardous materials" on our bikes or EV's by "motorized vehicle". Do you carry your battery pack at all times packed and labeled as a "Class 9 hazardous material," along with all the UN testing paperwork? Me neither. Maybe they won't enforce it, but do you want to be the one to find out that's not the case? I don't have $50,000 in spare change lying around. If the DOT ever decides to enforce the letter of this law, it would shut down what all of us are doing.

Folks, I believe need to do something about this, and we will be far more effective if we work together. As a first step, please respond to me whether you are willing to be involved in doing something about this, at minimum by including your name on a letter we may compose to the DOT. And please forward this message to others you know in the industry. I will compile a master list of all folks willing to sign on to an effort to respond to this, unless the LEV association and/or the EAA wants to take this on (and I will gladly join them in doing so).

The DOT contact I have listed for this issue is Charles Ke, phone 202-366-4495, 202-366-3753, and email Charles.Ke@dot.gov.

For more reading, look here:
http://www.prba.org/laws_and_regulation ... fault.ashx

Depending on the willingness (or lack thereof) of the DOT to respond to this issue, we may need to try to get some of our congressional representatives onboard with a change in the law about this. I look forward to hearing from you.


Sincerely,
Dr. Morgan Giddings
CTO, Cycle 9, LLC
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Fines up to $50,000 for shipping lithium ion batteries!

Post by E-BikeKit.com » Sat Jun 27, 2009 9:10 am

Taken from an email from Dr. Morgan Giddings, CTO, Cycle 9, LLC

Dear electric vehicle sellers and enthusiasts:

The US Department of Transportation can levy fines up to $50,000 fine per infraction for shipping any type of lithium ion battery, which includes LiFePO4, without packaging it and marking it as "class 9 hazardous material," and having the full UN testing regimen for each and every battery pack type you sell (which is a destructive test of at least 5-10 complete battery packs of each type). Each of your employees shipping such batteries must be trained and certified as hazardous materials shippers. If an end-user of a lithium pack ever has problems with it and needs to send it back, they will be in non-compliance with this law, and could also be fined $50k per infraction.

Folks, this is no joke. At least one person I know has already encountered this issue, with fines yet to be determined.

The DOT are serious about enforcing it. It seems to apply to road, air, and public waterway transportation in the US. All rechargeable lithium ion batteries with above 25g (that's grams) of lithium are classified this way. That threshold is the equivalent of a 24 volt 10 amp hour pack. If you ship any type of lithium battery in quantities larger than that, this DOT rule applies to you (and me). Smaller batteries can be excepted in some circumstances, but few e-bike or EV batteries are smaller than that.

See the message below that I received today from George Kirshner of the "portable battery manufacturer's association." In that message he goes so far as to suggest that people could make anonymous tips about people shipping li-ion batteries in non-compliance. He makes no distinction among battery types, he and his organization, in dealing with DOT, treat all li-ion batteries the same. There is no exception for electric vehicles, or LiFePO4.

Most importantly, they do not acknowledge the inherent safety differences between a chemistry like LiCoO2 (which I would never put on my bike) versus LiFePO4 (which I gladly use on my bike). In my own experience, we've had more concerns over problems with NiCd and NiMH packs, than with LiFePO4. Yet for the purposes of DOT, LiFePO4 is a Class 9 Hazardous material, whereas the Nickel batteries are not. I think this is because people like George represent laptop and cell phone manufacturers, and those are the folks who have the clout (so far) with the DOT. They mostly deal with LiCoO2 because of its higher energy density (but also worse safety). The needs of a laptop or cell phone are quite different than an EV or LEV. We need to get the DOT on the right page here.

Some of you may think that it is easy to slip under the radar. But if there is ever an incident involving one of your batteries, the fines can increase to $100k per infraction (and they can charge for multiple infractions per incident). It is real.

And it gets worse.

Today, i realized that all of us who use a light electric vehicle with lithium batteries are carrying those batteries on public roads. That means we fall under the auspices of DOT. Technically, we are each therefore transporting "Class 9 hazardous materials" on our bikes or EV's by "motorized vehicle". Do you carry your battery pack at all times packed and labeled as a "Class 9 hazardous material," along with all the UN testing paperwork? Me neither. Maybe they won't enforce it, but do you want to be the one to find out that's not the case? I don't have $50,000 in spare change lying around. If the DOT ever decides to enforce the letter of this law, it would shut down what all of us are doing.

Folks, I believe need to do something about this, and we will be far more effective if we work together. As a first step, please respond to me whether you are willing to be involved in doing something about this, at minimum by including your name on a letter we may compose to the DOT. And please forward this message to others you know in the industry. I will compile a master list of all folks willing to sign on to an effort to respond to this, unless the LEV association and/or the EAA wants to take this on (and I will gladly join them in doing so).

The DOT contact I have listed for this issue is Charles Ke, phone 202-366-4495, 202-366-3753, and email Charles.Ke@dot.gov.

For more reading, look here:
http://www.prba.org/laws_and_regulation ... fault.ashx

Depending on the willingness (or lack thereof) of the DOT to respond to this issue, we may need to try to get some of our congressional representatives onboard with a change in the law about this. I look forward to hearing from you.


Sincerely,
Dr. Morgan Giddings
CTO, Cycle 9, LLC
http://www.cycle9.com

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E-BikeKit.com
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Fines up to $50,000 for shipping lithium ion batteries!

Post by E-BikeKit.com » Sat Jun 27, 2009 9:10 am

Taken from an email from Dr. Morgan Giddings, CTO, Cycle 9, LLC

Dear electric vehicle sellers and enthusiasts:

The US Department of Transportation can levy fines up to $50,000 fine per infraction for shipping any type of lithium ion battery, which includes LiFePO4, without packaging it and marking it as "class 9 hazardous material," and having the full UN testing regimen for each and every battery pack type you sell (which is a destructive test of at least 5-10 complete battery packs of each type). Each of your employees shipping such batteries must be trained and certified as hazardous materials shippers. If an end-user of a lithium pack ever has problems with it and needs to send it back, they will be in non-compliance with this law, and could also be fined $50k per infraction.

Folks, this is no joke. At least one person I know has already encountered this issue, with fines yet to be determined.

The DOT are serious about enforcing it. It seems to apply to road, air, and public waterway transportation in the US. All rechargeable lithium ion batteries with above 25g (that's grams) of lithium are classified this way. That threshold is the equivalent of a 24 volt 10 amp hour pack. If you ship any type of lithium battery in quantities larger than that, this DOT rule applies to you (and me). Smaller batteries can be excepted in some circumstances, but few e-bike or EV batteries are smaller than that.

See the message below that I received today from George Kirshner of the "portable battery manufacturer's association." In that message he goes so far as to suggest that people could make anonymous tips about people shipping li-ion batteries in non-compliance. He makes no distinction among battery types, he and his organization, in dealing with DOT, treat all li-ion batteries the same. There is no exception for electric vehicles, or LiFePO4.

Most importantly, they do not acknowledge the inherent safety differences between a chemistry like LiCoO2 (which I would never put on my bike) versus LiFePO4 (which I gladly use on my bike). In my own experience, we've had more concerns over problems with NiCd and NiMH packs, than with LiFePO4. Yet for the purposes of DOT, LiFePO4 is a Class 9 Hazardous material, whereas the Nickel batteries are not. I think this is because people like George represent laptop and cell phone manufacturers, and those are the folks who have the clout (so far) with the DOT. They mostly deal with LiCoO2 because of its higher energy density (but also worse safety). The needs of a laptop or cell phone are quite different than an EV or LEV. We need to get the DOT on the right page here.

Some of you may think that it is easy to slip under the radar. But if there is ever an incident involving one of your batteries, the fines can increase to $100k per infraction (and they can charge for multiple infractions per incident). It is real.

And it gets worse.

Today, i realized that all of us who use a light electric vehicle with lithium batteries are carrying those batteries on public roads. That means we fall under the auspices of DOT. Technically, we are each therefore transporting "Class 9 hazardous materials" on our bikes or EV's by "motorized vehicle". Do you carry your battery pack at all times packed and labeled as a "Class 9 hazardous material," along with all the UN testing paperwork? Me neither. Maybe they won't enforce it, but do you want to be the one to find out that's not the case? I don't have $50,000 in spare change lying around. If the DOT ever decides to enforce the letter of this law, it would shut down what all of us are doing.

Folks, I believe need to do something about this, and we will be far more effective if we work together. As a first step, please respond to me whether you are willing to be involved in doing something about this, at minimum by including your name on a letter we may compose to the DOT. And please forward this message to others you know in the industry. I will compile a master list of all folks willing to sign on to an effort to respond to this, unless the LEV association and/or the EAA wants to take this on (and I will gladly join them in doing so).

The DOT contact I have listed for this issue is Charles Ke, phone 202-366-4495, 202-366-3753, and email Charles.Ke@dot.gov.

For more reading, look here:
http://www.prba.org/laws_and_regulation ... fault.ashx

Depending on the willingness (or lack thereof) of the DOT to respond to this issue, we may need to try to get some of our congressional representatives onboard with a change in the law about this. I look forward to hearing from you.


Sincerely,
Dr. Morgan Giddings
CTO, Cycle 9, LLC
http://www.cycle9.com

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Re: Fines up to $50,000 for shipping lithium ion batteries!

Post by gogo » Sat Jun 27, 2009 9:25 am

E-BikeKit.com wrote:And it gets worse.

Today, i realized that all of us who use a light electric vehicle with lithium batteries are carrying those batteries on public roads. That means we fall under the auspices of DOT. Technically, we are each therefore transporting "Class 9 hazardous materials" on our bikes or EV's by "motorized vehicle". Do you carry your battery pack at all times packed and labeled as a "Class 9 hazardous material," along with all the UN testing paperwork? Me neither. Maybe they won't enforce it, but do you want to be the one to find out that's not the case? I don't have $50,000 in spare change lying around. If the DOT ever decides to enforce the letter of this law, it would shut down what all of us are doing.

Regulations for shipping don't apply to final use/installed situations.

And 25g equivalency is 300 Wh per battery, not 24V 10Ah (Which would be 240 Wh).
"A conclusion is the place where you got tired of thinking." -Steven Wright

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