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Is This Lithium Battery Marking Compliant or Not?

Posted on 3/30/2020 by Roger Marks

Recently a friend of mine ordered a special computer for playing high-powered games. When his new PC got delivered, the packaging caught my eye. The package included a lithium battery mark that made me think “Wait, is that compliant?” Noncompliant lithium marking

This marking tells a story, and I think it raises an important point for every business that ships lithium battery powered devices and equipment (or any other regulated hazardous material). 

To the right, you can see what the lithium battery mark on my friend's computer package looked like.

That lithium battery mark is definitely stylish. I like the way the red, black, and white look together. But there are no style points in hazmat compliance.

The question that matters is: Is this a compliant lithium battery marking?

Let’s Go to the Hazmat Regs

For US shippers, the criteria for this lithium battery mark is found at 49 CFR 173.185(c)(3)(i)(B). In international regulations, the same requirements can be found in the IATA DGR (IATA 7.1.5.5.3) and the IMDG Code (IMDG 5.2.1.10.2).

49 CFR 173.185(c)(3)(i)(B) reads:  

“The symbols and letters must be black on white or suitable contrasting background and the hatching must be red...”

Let’s break that regulation down into three separate elements.
  1. Symbols and letters must be black
  2. Background must be white or a suitable contrasting color
  3. Hatching must be red
In other words, the lithium battery mark shown above is not compliant.

The symbols are white, the letters are white, and the background is black. The hatching is red, so score it one-for-three. Even though it looks cool, this alternate color scheme for the lithium battery mark is a violation of US and international hazardous materials regulations.

Errors like this cause shipments to be rejected or held up in transit on a constant basis. 

What Can We Learn From This?

A professional with knowledge about lithium battery regulations would have easily spotted this mistake and suggested that a compliant marking be used instead. In this case, it seems that the team in charge of package design made a choice based on artistic taste and not based on compliance.

Here's the lesson I think all businesses can learn: If you ship hazardous materials, don't forget to bring in at least one trained, knowledgeable professional to the package design process could save a major headache.  Your organization holds this knowledge, but if that knowledge is not applies to the right questions and situations, unforced errors will happen.

Last, if you don't have this knowledge in your organization, you should secure comprehensive training for one or more personnel who make decisions about packaging and shipping your product. Many avoidable hazardous materials violations stem from a lack of awareness about what materials are regulated, how they’re regulated, and what requirements the business must follow to maintain compliance.

Hazmat Training is Critical to Compliance 

Hazmat training is not just a smart business practice. In many cases, it's the law. US DOT requires all individuals who can affect the safety of hazardous materials in transport–including lithium batteries–to be trained once every three years. .  

If your product contains a lithium battery or another regulated hazardous material, strongly  consider hazmat training for more than just your shipping department. A general awareness of the regulations can help executives, decision makers, and even graphic designers ask the right questions when it comes to product packaging and transportation. 

This is especially true if your package includes a regulated marking, label, or other warning required by Federal, state, or local government, which often must meet very specific design and size requirements.  

When you take advantage of the hazardous materials knowledge in your organization, you can be confident that your package not only looks great, but will get where it needs to go without delay. 

Online Lithium Battery Shipper Training

Online lithium battery trainingNeed hazmat training to safely ship lithium batteries by ground, air, or vessel? Lion’s popular Shipping Lithium Batteries Online Course is updated regularly to cover the latest regulations you must know under 49 CFR, the IATA DGR, and the IMDG Code. 

Ship excepted lithium batteries by ground, air, or vessel? LIon's got a course just for you! The new Shipping Excepted Lithium Batteries Online Course will help you identify the requirements you must know, without getting bogged down or confused by rules for fully regulated lithium batteries.

Browse all lithium battery training courses at Lion.com/Lithium.  
 

Tags: hazmat shipping, lithium batteries, lithium marking, shipping lithium batteries

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