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Are Lithium Batteries Covered as Materials of Trade?

Posted on 11/12/2019 by Roger Marks

In today’s working world, we are constantly connected. Mobile phones, tablets, laptops and other devices make it possible to remain productive even when we can’t be at the facility, the site, or the office.

Many, if not all, of these devices are powered by lithium-ion batteries. If you’ve kept up with hazmat regulations over the past decade, you know that regulators have taken extensive action to address the hazards of lithium batteries in transit.

While phones and laptops are the most obvious examples, lithium batteries power a lot more than our personal electronics. A lawn care company may carry lithium batteries to power mowers, weed-wackers, leaf blowers, or other equipment, for example. So, are the lithium batteries we carry with us to support our business subject to the full burden of DOT's Hazardous Materials Regualtions (HMR)?

Lithium Batteries as MOTs

A recent PHMSA hazmat letter of interpretation (LOI) makes it clear that lithium batteries are covered under the exception for Materials of Trade (MOTs).

Clarification was needed because the Materials of Trade provisions at 49 CFR 173.6 provide package mass limits for materials in packing groups I, II, and III. But in 2015, PHMSA removed packing groups from articles, including lithium batteries.

In the recent LOI, PHMSA explains that they never intended to remove articles like lithium batteries from eligibility as Materials of Trade.

From the letter:

“Because lithium batteries are generally required to be offered in a packaging meeting PG II performance level as prescribed in 173.185(b)(3)(ii), lithium batteries transported as MOTs are subject to the same quantity limitations as a PG II hazardous materials (30 kg).”

Do your employees carry materials of trade to support your business? To take advantage of the MOTs exception, employees must know the specific requirements for carrying these materials. The Transporting Materials of Trade online course covers what you must know to maintain compliance. 

What is a "Material of Trade"?

In the 49 CFR  hazmat regulations, a "material of trade" is defined as a hazardous material carried in a motor vehicle for one of three purposes: 
  1. To protect the health and safety of the motor vehicle operator or passengers (such as a fire extinguisher in case of fire);
  2. To support the operation or maintenance of a motor vehicle (such as extra gasoline - or a spare battery - in the truck in case you run out); or
  3. By a private motor carrier (including vehicles operated by a rail carrier) in direct support of a principal business that is other than transportation.”
For #3, "in direct support of principal business that is other than transportation," the textbook example is a gardener carrying fuel for equipment and fertilizer in his company truck. With new applications for lithium batteries being brought to market constantly, equipment that once required gasoline may now be powered by a lithium battery.   

While materials of trade are excepted from many of the most burdensome hazmat shipping regulations, there are quantity limits and a few other specific requirements that must be followed. Not every hazard class is eligible for the MOT exception, and employees must be aware of the hazards of the materials they carry in a vehicle.

Courses to Ship Lithium Batteries in Full Compliance

Carrying a laptop with you in your car is one thing. Shipping a whole box of batteries is another.

Be confident that your personnel are properly trained to offer lithium batteries for transportation. Lion’s popular Shipping Lithium Batteries Online Course is updated regularly to cover the latest regulations that shippers must know under 49 CFR (US DOT), the IATA DGR, and the IMDG Code. 

New! Ship excepted lithium batteries by ground, air, or vessel? We’ve 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.

Tags: Hazmat regulations, lithium batteries, Lithium battery safety, lithium battery training, materials of trade

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