I have been told that I cannot ship lithium batteries as limited quantities, but can receive similar relief when following the special provisions found in the 171.101 Hazardous Materials Table. How do the two types of relief compare? A.
It is true that lithium batteries shipped under the DOT Hazardous Material Regulations cannot be shipped under the limited quantity exceptions. However, if properly classified and packaged, lithium batteries can receive as much or more relief from the regulations than limited quantity shipments. Unlike the limited quantities relief, which is found in the packing authorizations in column 8A of the 172.101 table, the relief for lithium batteries can be found as part of the special provisions listed in column 7.
When shipping hazardous materials as limited quantities, you get the following reliefs:
- Hazard labels are not required, except for air shipments
- Shipping papers and emergency response information are not required, except for hazardous substances, hazardous wastes, marine pollutants, or if transported by aircraft or vessel
- Placards are not required
- Specification packaging is not required, but
- packagings must still meet general requirements (49 CFR 173 Subpart B), and
- specific weight limitations apply (49 CFR 173.150-173.156)
Small and medium lithium batteries can receive relief from nearly all the Hazardous Material Regulations when following the special provisions in 49 CFR 172.102 (SP 29, 188, 189, and 190), additional restrictions and reliefs apply when shipping by air (A54, A55, A100, A101, A103, or A104).
The restrictions and procedures necessary to follow, however, can be more extensive, and may include:
- Being of a type proven to meet the testing requirements of the UN Manual of Tests and Criteria
- Meeting unique size restrictions for lithium primary vs. secondary lithium batteries
- Packaging cells or batteries to prevent short circuits
- Using strong outer packagings
- Primary (non-rechargeable) lithium batteries are largely prohibited for transport by air
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