Lithium Batteries Shipping Rules Discussions

[TylerDurden]

Considering the language in the DOT document, it is worth communicating the safety improvements in newer chemistries:

"Lithium batteries are considered a hazardous material for purposes of transportation regulation because they can overheat and ignite in certain conditions and, once ignited, can be especially difficult to extinguish. In general, the risks posed by lithium batteries are a function of battery size (the amount of lithium content and corresponding energy density) and the likelihood of short-circuiting or rupture. By comparison to standard alkaline batteries, most lithium-ion batteries manufactured today contain a flammable electrolyte and have a very high energy density. A lithium battery is susceptible to thermal runaway, a chain reaction leading to self-heating and release of its stored energy."

A letter might illustrate that new chemistries are not subject to thermal runaway and therefore, should be considered exempt from hazmat class; but rather be regulated more like nickel-based and non-spillable batteries.

As GTA1 so charmingly points out, all battery chemistries can contain hazardous levels of energy (depending on size), so it would be prudent to advocate safety measures consistently across all non-flammable chemistries.

On the PHMSA site, they also indicate the possibility of obtaining a special-permit:
"The Pipeline and Hazardous Materials Safety Administration has the primary responsibility for the issuance of DOT Special Permits and Approvals to the Hazardous Materials Regulations (HMR). A Special Permit or Approval is a document which authorizes a person to perform a function that is not currently authorized under the authority of the HMR. "

The ULBI publication states that an "Approval" may take 16 weeks; I expect a special-permit might take longer.

The letter to the DOT might include an inquiry if any special permits have been issued for lithium cells of the non-flammable type.

 

[GTA1]

Much of the hazards of high capacity batteries can be mitigated by only transporting them in the full discharge state (providing that the chemistry is amenable to being stored for a time in the full discharge state without harm to the battery).

In fact, a common test is to short circuit the battery in question with a wire to confirm its "full discharge" state.


A very good compromise with the Feds on this would be regulations that permit high capacity batteries to be transported in a special compartment (Hazmat Cat. 9) in a full discharge state where such discharge is verified by the common carrier's agent at the time of shipping / packing.

That would satisfy most concerns, and possibly, permit higher amounts of lithium to be carried than the present limits, which makes e Bike motive batteries nearly impossible to transport by air.

 

[tostino]

Much of the hazards of high capacity batteries can be mitigated by only transporting them in the full discharge state (providing that the chemistry is amenable to being stored for a time in the full discharge state without harm to the battery).

In fact, a common test is to short circuit the battery in question with a wire to confirm its "full discharge" state.


A very good compromise with the Feds on this would be regulations that permit high capacity batteries to be transported in a special compartment (Hazmat Cat. 9) in a full discharge state where such discharge is verified by the common carrier's agent at the time of shipping / packing.

That would satisfy most concerns, and possibly, permit higher amounts of lithium to be carried than the present limits, which makes e Bike motive batteries nearly impossible to transport by air.

Can you point me towards a lithium based battery that takes kindly to being stored fully discharged (are we talking about 3.2v for lipo, and whatever lifepo4's low voltage is, or at 0v?)

I know lipo, and lifepo4 don't like to be stored at near empty, and if left that way for long periods will develop damage. And if you were talking about at 0v, than there is no lithium that I know of that will take being discharged like that and recover.

 

[TylerDurden]

The only chem I have seen allowed exemption for discharged capacity is LiMNO2.

I don't see a big problem with ebike packs being ground-only. It is an annoyance more than a hardship. (pardon the pun.)

 

[GTA1]

The only chem I have seen allowed exemption for discharged capacity is LiMNO2.

I don't see a big problem with ebike packs being ground-only. It is an annoyance more than a hardship. (pardon the pun.)

That would allay a lot of concerns at DOT.

The scuttlebutt is that incidents involving small (eg Cell Phone, iPhone, etc.) batteries are increasing --- especially because of the off brand products commonly sold around the world.

At this moment, data is being collected and analyzed before new regulations are proposed.

 

[tostino]

I don't see a big problem with ebike packs being ground-only. It is an annoyance more than a hardship. (pardon the pun.)

If this was only enforced for air shipping, I don't think there should be so many worries. What worries me is if it applies to all shipping, not only air.

 

[GTA1]

I don't see a big problem with ebike packs being ground-only. It is an annoyance more than a hardship. (pardon the pun.)

If this was only enforced for air shipping, I don't think there should be so many worries. What worries me is if it applies to all shipping, not only air.

There are a set of regulations for all modes of transport, and a stricter set for air transport.

Details are in the posts....

 

[knightmb]

Much of the hazards of high capacity batteries can be mitigated by only transporting them in the full discharge state (providing that the chemistry is amenable to being stored for a time in the full discharge state without harm to the battery).

In fact, a common test is to short circuit the battery in question with a wire to confirm its "full discharge" state.


A very good compromise with the Feds on this would be regulations that permit high capacity batteries to be transported in a special compartment (Hazmat Cat. 9) in a full discharge state where such discharge is verified by the common carrier's agent at the time of shipping / packing.

That would satisfy most concerns, and possibly, permit higher amounts of lithium to be carried than the present limits, which makes e Bike motive batteries nearly impossible to transport by air.

Can you point me towards a lithium based battery that takes kindly to being stored fully discharged (are we talking about 3.2v for lipo, and whatever lifepo4's low voltage is, or at 0v?)

I know lipo, and lifepo4 don't like to be stored at near empty, and if left that way for long periods will develop damage. And if you were talking about at 0v, than there is no lithium that I know of that will take being discharged like that and recover.

None that I know of, but that doesn't mean you can't leave them at least 20% charged. If you have a 48 volt 20AH battery at only 20% capacity, it's like having a 48 volt 4AH battery in which it only has 192 watt/hour power available. If they are going to throw out the 300 number, then I say exploit that because the science is there to back it up.

Would you be expecting months between deliver times before someone gets to put it on the charger?

 

[GTA1]

Can you point me towards a lithium based battery that takes kindly to being stored fully discharged (are we talking about 3.2v for lipo, and whatever lifepo4's low voltage is, or at 0v?)

I know lipo, and lifepo4 don't like to be stored at near empty, and if left that way for long periods will develop damage. And if you were talking about at 0v, than there is no lithium that I know of that will take being discharged like that and recover.

None that I know of, but that doesn't mean you can't leave them at least 20% charged. If you have a 48 volt 20AH battery at only 20% capacity, it's like having a 48 volt 4AH battery in which it only has 192 watt/hour power available. If they are going to throw out the 300 number, then I say exploit that because the science is there to back it up.

Would you be expecting months between deliver times before someone gets to put it on the charger?

I would like to know what are the short term consequences of having lithium based chemistries stored fully discharged (most of them come from the factory partially charged).

If that cannot be done without damaging the battery, then that route is a non-starter.

If you were to play the game of saying the battery is 20% charged and therefore it is under the 300 watt limit.... that is a real quick way to land yourself on the DOT target list.

How about playing by the rules instead of figuring out "exploits"?

Be rest assured that if you were caught doing that, and it resulted in a serious incident, this post of yours will be evidence against you.

 

[TylerDurden]

How about playing by the rules instead of figuring out "exploits"?

Making use of 'exploits' is playing by the rules... to one's advantage (like tax-loopholes). Otherwise, it's just plain cheating/lying/fraud. A moot point anyway, we're discussing allowable solutions.

The goal is to avoid another ValueJet and still keep the little guys legally in business. The cost of testing and training puts the big guys at a significant advantage.

 

[GTA1]

How about playing by the rules instead of figuring out "exploits"?

Making use of 'exploits' is playing by the rules... to one's advantage (like tax-loopholes). Otherwise, it's just plain cheating/lying/fraud. A moot point anyway, we're discussing allowable solutions.

The goal is to avoid another ValueJet and still keep the little guys legally in business. The cost of testing and training puts the big guys at a significant advantage.

The above "exploit" (claiming a battery pack is below the 300w limit) because it is only partially charged, is flagrantly in violation of HMR.

Lawful compliance in letter and in spirit of HMR hat may be imaginative, sure!


I concur that keeping the little guys in business is a laudable goal --- the question is how to devise a regulatory system that does that without shrinking the supplier base to a couple of large firms.


Can someone explain to me the scientific, technical, and other reasons why Lithium secondary batteries cannot be fully discharged without harm?

 

[julesa]

Can someone explain to me the scientific, technical, and other reasons why Lithium secondary batteries cannot be fully discharged without harm?

Sure, here you go:
http://lmgtfy.com/?q="effects+of+overdischarge"+lithium-ion

 

[cycle9]

After re-reading the HMR, I concur with Dave Kois.

I have also done further reading since posting. I think there is confusion stemming from the fact that there are multiple rulings with distinct dates. The2007 ruling seems to be in full effect, and in that ruling, a "large" battery must be shipped as Class 9 Hazmat, and have UN 38.3 testing. The 2009 proposed harmonization has not been put in full effect, which would (according to George Kerchner of PRBA) eliminate any exemptions for "medium" sized batteries, and make other rules stricter. I think that Dave is just looking at the 2009 stuff, but not taking the 2007 ruling into account.

So the best I can figure it so far (and I'm still researching), the 2007 ruling does apply right now to any "large" battery over 25g of lithium content.

I do know of one or two people in this industry who have already been certified and are shipping batteries this way. It costs the consumer up to almost $200 additional for each battery.

I really, really wish Dave Kois were right, but I don't have any solid evidence yet that he is.

BTW - George also told me on the phone that there is new US legislation being considered right now, that would further stiffen the regulations. Apparently the airline pilot's association is behind that.

I'm thinking one tack to approach this is to differentiate between shipping modes. Most of us seem to agree that shipping these on passenger aircraft is a bad idea. But if the regulations get implemented such that shipping by ground is treated in the same way as shipping by passenger craft (as they appear to be right now), this will make life difficult for all.

BTW - there is an apparent exemption for shipping the batteries as part of end-user equipment. That's how the Segway can be shipped without having this problem. This seems like another avenue to consider, though I need to read more about it to find out exactly how this is defined.

Morgan

 

[frodus]

I've been on hold all morning with the IATA... nothing.

I'm in contact with a freight shipper in the US, we're working on finding more out.

Some of you are just quoting the material you read online... get involved, make some calls, do some work... Get the real story.

 

[John in CR]

I've been on hold all morning with the IATA... nothing.

I'm in contact with a freight shipper in the US, we're working on finding more out.

Some of you are just quoting the material you read online... get involved, make some calls, do some work... Get the real story.

We should come up with a form letter to all send to our congressmen and Big O.

 

[cycle9]

There are a few other things we can do as a community.

1. Join the light electric vehicle association. I have an email from them today, indicating they are going to take this issue on. Individual membership is $25, and I believe that will be money very well spent by representing us and reducing everyone's future costs in buying LiFePO4 and other batteries.

2. Contact DOT (politely, please). The contact person I see listed for this issue is Charles Ke, Charles.Ke@dot.gov, 202-366-4495. See below for more information about what you might discuss with him.

3. Contact your representatives. There is apparently legislation brewing (which I will post here as soon as I have a copy) that would strengthen the Lithium battery requirements. It is supposedly backed by the Airline Pilots Association. Many congresspeople don't want to be seen as "against safety," so unless they hear from us, our interests will not be represented. Your house members can be found at: https://writerep.house.gov/writerep/welcome.shtml and your senators at: http://www.senate.gov/general/contact_information/senators_cfm.cfm. I would suggest talking to them about the differences between ground/boat shipping and air shipping, and that they deserve distinct regulations, not one blanket regulation that shuts it all down.

4. We need real world data, documented on video. The more people that are willing to take cells and do tests like putting them in the fire (under controlled, safe conditions!!!), to document what really happens, the more evidence we will have one way or another.

I was told today that the DOT beef with LiFePO4 stems from concerns over the flammability of the solvents used. They apparently cite a Prius that caught on fire with A123 cells onboard. I searched for that incident, found a short thread here about it, but someone claimed that "the battery pack was still mostly functional". More data about the nature of this (and any similar) incidents would help. We need to know whether the solvents are flammable, and if so, how flammable. Without such evidence, I think we will be speaking to deaf ears. The evidence to date I have is that these are not very flammable, but I haven't yet put a torch to any of our PSI cells or polymer LiFePO4 cells. I plan to do that, but it will take time to set up safe conditions for such testing.

I've been on hold all morning with the IATA... nothing.

I'm in contact with a freight shipper in the US, we're working on finding more out.

Some of you are just quoting the material you read online... get involved, make some calls, do some work... Get the real story.

We should come up with a form letter to all send to our congressmen and Big O.

 

[TylerDurden]

4. We need real world data, documented on video. The more people that are willing to take cells and do tests like putting them in the fire (under controlled, safe conditions!!!), to document what really happens, the more evidence we will have one way or another.

Domestic mfrs. like Valence, Emoli, A123, LifeBatt and some international mfrs. should have MSDSs for cells already, along with other safety info.

Testing might be better left to accredited labs.


The big-buzz right now is economic impact and local enterprise. Ebike/cycle shops can draft projections of hardship due to cost increases and time penalties, and send those to the powers-that-be.

Spinning the issue to depict the restrictions as hamfisted and anti-small-business will put legislators under the gun to advocate intelligent safety measures that can benefit business owners in their region... they should recognize that the political penalties for blindly siding with big-business and ignoring small-enterprise can be significant in the era of youtube and blogspot.

 

[cycle9]

Yes, when I wrote the thing about testing, I almost deleted it for this reason.

But here's the thing - those manufacturers don't seem to have effectively communicated to the DOT and others about the differences with these cells. And to my knowledge, they don't post their test results on Youtube or other places where we can use them as evidence to support our case. So unless someone can afford high-end testing, what other options are there?

As for the MSDS, their value appears limited. For the PSI cells, the MSDS lists the only "hazard" as Polyvinylidene difluoride, but the flammability is not listed. An online search does not indicate flammability, but one site did claim that the byproducts of thermal breakdown include fluorine gas.

Doing more research, it seems that this isn't even the solvent - it is a plastic like material, that they may use as the cathode/anode separator. So the MSDS doesn't reveal what the solvent is.

Side note: Are you the same Tyler Durden that writes for Zero Hedge?

4. We need real world data, documented on video. The more people that are willing to take cells and do tests like putting them in the fire (under controlled, safe conditions!!!), to document what really happens, the more evidence we will have one way or another.

Domestic mfrs. like Valence, Emoli, A123, LifeBatt and some international mfrs. should have MSDSs for cells already, along with other safety info.

Testing might be better left to accredited labs.


The big-buzz right now is economic impact and local enterprise. Ebike/cycle shops can draft projections of hardship due to cost increases and time penalties, and send those to the powers-that-be.

Spinning the issue to depict the restrictions as hamfisted and anti-small-business will put legislators under the gun to advocate intelligent safety measures that can benefit business owners in their region... they should recognize that the political penalties for blindly siding with big-business and ignoring small-enterprise can be significant in the era of youtube and blogspot.

 

[GTA1]

Testing might be better left to accredited labs.


The big-buzz right now is economic impact and local enterprise. Ebike/cycle shops can draft projections of hardship due to cost increases and time penalties, and send those to the powers-that-be.

Spinning the issue to depict the restrictions as hamfisted and anti-small-business will put legislators under the gun to advocate intelligent safety measures that can benefit business owners in their region... they should recognize that the political penalties for blindly siding with big-business and ignoring small-enterprise can be significant in the era of youtube and blogspot.

The only testing that have any credibility would be testing by major, name brand accredited labs like UL, etc.

As for contacting elected reps... it might be a good idea to get facts straight first... and acknowledge the legitimate concerns that DOT and other parties have about this issue... and help CONSTRUCTIVELY craft a sensible solution.


I would not put too much credence on small business and local job creation until legitimate safety concerns are addressed.

Off hand, I do not see a way out of sharply limiting the unrestricted shipment of cells and battery packs (any chemistry, any size) unless they are from trusted, reputable, accredited manufacturers (which do not preclude businesses of any size, including very small ones), providing they meet the safety standards.

With this type of administrative infrastructure needed to safely handle batteries will come higher costs.

The wild west days when people can hand carry (or stick in checked baggage) batteries of unknown quality and safety certification on commercial aircraft need to end.

e Vehicles use high capacity batteries --- or must use them, should I say.

With this capability e Vehicle users, builders, and distributors must assume a level of responsibility for potential consequences regardless of whether the e vehicle is the initial cause of the problem.

That include paying the bills needed to ensure safe handling and transport.

 

[TylerDurden]

With this capability e Vehicle users, builders, and distributors must assume a level of responsibility for potential consequences regardless of whether the e vehicle is the initial cause of the problem.

That 'level of responsibility' being measured by the supplied components ability to contribute to the overall safety of the system, in a fashion that adequately exercises reasonable due-diligence.

Safety should be ensured, using standards that do not overburden shops with overkill restrictions; such as requiring non-flammable materials be handled as though they were flammable.

 

[GTA1]

That 'level of responsibility' being measured by the supplied components ability to contribute to the overall safety of the system, in a fashion that adequately exercises reasonable due-diligence.

Safety should be ensured, using standards that do not overburden shops with overkill restrictions; such as requiring non-flammable materials be handled as though they were flammable.

Agreed.


There are legitimate issues to raise with PHMSA to ensure that they get their facts right, and then make such adjustments in product design, packaging, etc. that make the product meet their needs, preferably with the least onerous regulations.

 

[michaelplogue]

BTW - there is an apparent exemption for shipping the batteries as part of end-user equipment. That's how the Segway can be shipped without having this problem.

I would assume the PMW has a similar exemption for shipping their Goped Lithium Hoverboards.

If that all it takes (for shipping the batteries as part of end-user equipment), then just put the packs in a pretty box, slap a lightbulb on it, and PRESTO: One emergency lighting module! :wink:

 

[TPA]

Just received bosch tool packs from max tool, thought you might find a label on the box interesting (other than it being upside down). There was no other information or labels. More info on the batteries themselves in the batteries section in the bosch thread.

 

[KAE]

Tonight we celebrate our freedom. Part of that entails doing what we feel is right, even in the face of insurmountable odds. We do what is right, beyond the worries of money, of society, of greed, of power. Remember why you began on this path, and why you continue to follow it, and let no one stand in your way. Happy 4th of July!

 

[tomas]

Hi Guys, I am currently looking at LiFePO4 batteries, could somebody tell me if they are classified as lithium ion or lithium metal batteries as this can have a big difference regarding the air transport regulations that I need to abide by. Any info would be great.