In response to the ongoing recall of Samsung Galaxy Note 7 smartphones
, the US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) has granted an emergency special permit to Samsung Electronics America, Inc.
The emergency special permit—DOT-SP 20325—allows the company to use alternative packaging to ship its recalled smartphones by motor vehicle, rail, and cargo vessel. Electronics that contain lithium batteries are regulated under the Hazardous Materials Regulations (HMR) as UN3481, “lithium ion batteries contained in equipment.”
Special requirements apply to lithium batteries deemed “damaged” or “defective.” Under the emergency special permit, Samsung can ship its recalled smartphones in unopened, factory-sealed packagings originally used to transport the products before it was known that the batteries were possibly defective.
Samsung applied for the special permit on September 7, 2016. See a copy of the special permit here.
Shipping Damaged or Defective Lithium Batteries
Typically, to ship damaged or defective lithium batteries, manufacturers and shippers must follow specific instructions for packaging found at 49 CFR 173.185(f).
Each damaged or defective lithium battery or cell must be completely enclosed in individual, non-metallic inner packaging surrounded with non-combustible, non-conductive, absorbent cushioning material. The outer packaging used must be suitable for Packing Group 1 level materials and must be marked to indicate it contains a “damaged/defective lithium ion battery” or “damaged/defective lithium metal battery.”
US DOT released a safety advisory notice on defective or damaged lithium batteries
in the September 22 Federal Register.