Deciphering the Transport Requirements for Used Lithium Batteries

Non damaged cells or batteries for disposal or recycling

*Based on the ADGC edition 7.8

The use of Lithium batteries to power our way of life is expanding exponentially and with it the need to safely recycle them when they have reached their end of life. Due to the large amount of energy stored in even small batteries they can cause fires and / or explode. Consequently, they are classified as a Dangerous Good in the Australian code for the Transportation of Dangerous Goods (ADGC).

The road and rail transport requirements laid out in the ADGC for Lithium Batteries are complex and not easily understood. I have written this article in an attempted to help explain them in layman terms. The ADGC code is updated from the UN model dangerous good regulations, so both are usually identical.

This article doesn’t cover the requirements for air and sea transport of Lithium batteries. For this you will need to refer to the Civil Aviation Safety Authority and Australian Maritime Safety Authority regulations.

If you are wanting to find out about the ADGC regulations for transporting used lead acid batteries, then read here.

I should at this point mention a disclaimer, that what follows is my best endeavours to interpret the ADGC requirements after extensive reading and re-reading of the code. That said there is always some ambiguity or possibility of misinterpretation of the regulations. Given the dangerous nature of Lithium batteries and the potential for catastrophic outcomes, it would be advisable to seek alternative opinions.

Identifying Lithium Batteries

Lithium batteries are used to power many modern electronic devices, from mobile phone. Laptops, cameras, power tools, toys and many other industrial devices. They come in all shapes and sizes and often form part of the equipment they are installed in where the battery should only be removed by a professional (think some jump starter packs, UPS backup systems).

The photo below depicts 3 batteries with different chemistries. The only way to distinguish which of these batteries is a Lithium battery is by inspecting the description on the battery.

Photo showing 3 AAA Batteries with different chemistries
One battery is Alkaline, another Zinc Carbon and the 3rd Lithium. Do you know which?

Larger Lithium batteries (1 kg or more) can also be distinguished from the more common lead acid batteries by their weight. Lithium batteries are much lighter than the equivalent sized lead acid batteries.

Some examples of different Lithium batteries are show below, however the best method to identify them from other battery chemistries, is to look for the word “Lithium” or the chemical symbol “Li”.

Packaging Used Lithium Batteries for Transport – the ADGC Requirements

What follows is an explanation of the packing instructions for transporting non-damaged Lithium batteries for the purpose of disposal or recycling. To not overwhelm the reader, I have excluded the requirements for:

  • transporting damaged or defective Lithium batteries.
  • transporting Lithium batteries contained in equipment (e.g. UPS, Battery Chargers)

I will cover these requirements in future articles.

Below is the ADGC Packing Instruction P909 that applies to transporting non-damaged Lithium batteries for the purpose of disposal or recycling.

ADGC Packing Instruction P909 for the transport of non damaged used Lithium batteries by road or rail

I suspect most people when they first read the instructions will be confused, so let’s see if I can help de-mystify the requirements for you. Let’s start with some useful definitions;

Definitions

Cell vs a Battery: A cell is defined as a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals and may contain a protective device. A Battery is two or more cells or batteries which are electrically connected together and fitted with devices necessary for use, such as a case, terminals, marking or protective devices (definitions from the UN’s Manual of Tests & Criteria)

Is it always easy to distinguish whether you’re dealing with a cell or battery? No, not in my opinion. So, for example would you think the Li battery used on power tools is a cell or battery? From the above definition I would have guessed it was a Cell. It is only by looking at the Safety Data Sheet for the battery that you can determine that it is actually a Battery made of several Cells.

Lithium Ion: These batteries are generally rechargeable i.e. power tools, mobile phones, laptops

Lithium Metal: These batteries are not rechargeable i.e can only be used once such as AA & AAA Energizer Lithium batteries.

Packaging: means one or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions. For some Lithium cells / batteries only authorised packagings can be used (see flowchart below to determine when they are required).

The authorised packaging needs to have passed UN Certification requirements, as outlined in the ADGC, for the intended purpose, in this case transporting Lithium batteries. The receptacle must display the appropriate UN Certification markings.

Clause 1 of the P909 Packing Instructions lists the acceptable packagings (drums, boxes, jerricans). A mark commencing with the letter UN and followed by the packaging type (e.g UN4H2/… for plastic boxes) must be displayed on the packaging. The presence of one of the allowed marks doesn’t mean the packaging is suitable for Lithium Batteries. You will need to check the UN Certification test report from the supplier to ensure that the packaging’s testings are adequate for Lithium Batteries.

Damaged or Deflective: Includes lithium cells / batteries that are have leaked or vented, sustained physical or mechanical damage, cannot be diagnosed prior to transport or have been identified as being defective for safety reasons.

UN Numbers: The following Dangerous Goods UN Numbers apply to Lithium Cells / Batteries,

  • UN3480 – Lithium Ion Batteries (including lithium polymer batteries)
  • UN3481 – Lithium Ion Batteries Contained in Equipment or Packed with Equipment
  • UN3090 – Lithium Metal Batteries (including lithium polymer batteries)
  • UN3091 – Lithium Metal Batteries Contained in Equipment or Packed with Equipment

The first thing we need to determine is what receptacle can the Lithium batteries be transported in – referred to as “Packagings” in the ADGC. This will depend upon the type of Lithium batteries you have and the quantity. The decision chart below should help you determine whether you need to use an authorised package or not.

Note: The decision chart does not apply to cells or batteries contained in equipment. See Used Lithium Batteries Contained in Equipment.

Decision chart to help determine suitable packaging for transporting non damaged, used lithium batteries, as defined by the ADGC

The Threshold Test & Authorised Packaging

Lithium Ion Cells / Batteries (rechargeable)

For Lithium Ion cells if the Watt-hour rating doesn’t exceed 20Wh and for Lithium Ion Batteries doesn’t exceed 100Wh, then the cells / batteries can be transported in a strong but non-authorised package. This includes all small hand-held batteries and most power tools. If you’re unsure check the battery labels or safety data sheet.

If the cell / battery exceeds these thresholds, generally larger batteries, then an authorised packaging must be used, as stipulated in the P909 Packaging Instruction Clause 1 (a). Again, if you’re unsure check the battery labels or safety data sheet.

Lithium Metal Cells / Batteries (non-rechargeable)

For Lithium metal cells if the lithium content doesn’t exceed 1g and for Lithium Metal Batteries doesn’t exceed 2g, then the cells / batteries can be transported in a strong but non-authorised package. This includes all small hand-held batteries. If you’re unsure check the battery labels or safety data sheet.

If the cell / battery exceeds these thresholds, then an authorised packaging must be used, as stipulated in the P909 Packaging Instruction Clause 1 (a) – see P909 above. Again, if you’re unsure check the battery labels or safety data sheet.

Note: Lithium Batteries can be packed with other battery chemistries, however there presence dictates that all the batteries must be transported as per the requirements for Lithium batteries. Due to the difficulty of easily identifying the presence of lithium batteries in a mixture of portable, handheld batteries, my rule of thumb is “if in doubt assume the presence of some Lithium batteries”.

The “P909 Additional Requirements”

Now that you have determined what packagings are allowed for transporting your Lithium Cells / Batteries, you will now need to ensure they are packaged correctly.

The P909 Packing Instructions, include some “Additional Requirements”, which outline these requirements. The “Additional Requirements” are,

1.  Cells and batteries must be designed or packed to prevent short circuits and the dangerous evolution of heat.

2.  Protection against short circuits and the dangerous evolution of heat includes, but is not limited to,

  • individual protection of the battery terminals,
  • inner packaging to prevent contact between cells and batteries,
  • batteries with recessed terminals designed to protect against short circuits, or
  • the use of an electrically non-conductive and non-combustible cushioning material to fill empty space between the cells or batteries in the packaging.

3.  Cells and batteries must be secured within the outer packaging to prevent excessive movement during transport (e.g. by using a non-combustible and electrically non-conductive cushioning material or through the use of a tightly closed plastics bag).

So, let’s look at what this might mean for different types of Lithium Cells & Batteries

Handheld Lithium Batteries

This includes batteries, such as AA, AAA, AAAA, D, C, 9V batteries, button, mobile, laptop batteries etc

The most common method deployed to individually protect battery terminals is to tape each terminal. I think the expectation to individually tape the terminals of every AA, AAA, C, D & button battery is unrealistic and doesn’t match industry current practices. Similarly, to expect every battery to be placed in an “inner packaging” is also unlikely and again does not match industry current practices. I would be concerned that these requirements would result in very low recycling rates for these batteries and result in more batteries going to landfill – the very outcome the industry is trying to avoid.

Common solutions available in Australia involve the placement of these batteries in a fire-retardant bag that is then placed inside a sturdy cardboard box. The batteries are often mixed with non-lithium batteries which is allowed under the P909 requirements.

Non-Handheld Lithium Batteries

My definition for this is the larger Lithium batteries typically weighing more than 1kg.

For these larger batteries it is more practical to protect the battery terminals and provide inner packaging to prevent the batteries from contacting each other. This could be achieved using individual, non-conductive, non-combustible bags or foam.

Used Lithium Batteries Contained in Equipment

Clause 3 of the P909 Packing instructions details the requirements when transporting used lithium cells / batteries contained in equipment, for the purpose of disposal or recycling. The clause states:

For cells or batteries contained in equipment, strong outer packagings constructed of suit- able material, and of adequate strength and design in relation to the packaging capacity and its intended use, may be used. Packagings need not meet the requirements of
4.1.1.3. Equipment may also be offered for transport unpackaged or on pallets when the cells or batteries are afforded equivalent protection by the equipment in which they are contained.

The exemption from meeting the requirements in 4.1.1.3 means that any packaging used does not need to be UN Certified.

The following UN Numbers and Proper Shipping Names apply for Lithium cells / batteries contained within equipment,

  • UN3481 – Lithium Ion Batteries Contained in Equipment or Packed with Equipment
  • UN3091 – Lithium Metal Batteries Contained in Equipment or Packed with Equipment

ADGC Special Provision for Lithium Batteries

There are a number of Special Provisions in the ADGC that apply to Lithium Batteries. A full summary of the ADGC’s Lithium battery Special Provisions can be found here.

Special Provisions 188 and 377 are of particular importance when transporting Lithium cells / batteries that don’t exceed the threshold test above for the purpose of disposal or recycling. See below for full details.

Transport Requirements for Lithium Batteries That Don’t Exceed the Threshold Test

Special Provision 188 essentially states that cells or batteries that don’t exceed the thresholds outlined in the Threshold Test above are not subject to other provisions of the ADGC code. This would apply to most handheld batteries (as outlined above) such that they only need to meet the requirements of the P909 Packing Instructions, the Special Provision 377 below and to display the Lithium Battery Mark shown in figure 2 to be suitable for transport. This means no labelling, markings, DG Documentation or Emergency information is required.

Special Provision 377 requires that cells or batteries being transported for the purpose of disposal or recycling must be marked “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING”

Lithium Battery Mark

Batteries prepared for disposal or recycling as per Special Provision 188 must display the Lithium Battery Mark shown below. The mark must indicate the UN Number, preceded by the letters “UN”, where the * is denoted. Where a package contains a combinations of Lithium cells or batteries with different UN Numbers (UN3480, 3481, 3090, 3091), all applicable UN Numbers shall be indicated on one or more marks.

The mark must be a minimum of 100 x 100mm in size with a 5mm red hatched border.

ADGC Lithium Ion Battery Mark

Transport Requirements for Lithium Batteries That Do Exceed the Threshold Test

If the Lithium batteries exceed the Threshold Test above then the batteries are subject to all the relevant ADGC provisions including labelling, markings, DG Documentation and Emergency Information. These are outlines below:

Labeling

  • 2 DG Diamonds Class 9a, minimum size of 100 x 100mm with minimum lettering size of 7mm, applied to opposite side of the package.
  • All packages must be labeled with the appropriate UN Number and proper shipping name – 12 mm minimum lettering ,(may include combinations)
    • UN3480 – Lithium Ion Batteries (including lithium polymer batteries)
    • UN3481 – Lithium Ion Batteries Contained in Equipment or Packed with Equipment
    • UN3090 – Lithium Metal Batteries (including lithium polymer batteries)
    • UN3481 – Lithium Metal Batteries Contained in Equipment or Packed with Equipment
  • All packages must display the Name, address and contact number of the consignor – minimum 12mm lettering.

Note: It is an offence under the ADGC to transport an empty packaging while displaying DG labels.

Load Restraint

  • Packages must be stowed & restrained in the vehicle in accordance with the National Transport Commission’s Load Restraint Guide 2018.
  • In addition Chapter 9.2 of the ADGC requires that batteries being transported with incompatible dangerous goods or other goods, must be segregated. Note that when batteries are transported with other goods all goods must be restrained to prevent damage to the batteries and release of their electrolyte.

Dangerous Good Transport Documentation

  • The Consignor who provides the used Lithium cells / batteries for transport shall provide the transport contractor information applicable to those dangerous goods.
  • The documentation must be carried in the vehicle in hard copy form
  • The documentation must include the name and address of the consignor, consignee, including the consignor’s contact telephone number
  • The documentation should include the following information
    • UN Number – UN3480, 3481, 3090, 3091 or combination of.
    • Proper Shipping Name – either or combination of Lithium Ion Batteries (including lithium polymer batteries), Lithium Ion Batteries Contained in Equipment or Packed with Equipment, Lithium Metal Batteries (including lithium polymer batteries), Lithium Metal Batteries Contained in Equipment or Packed with Equipment
    • DG Class – 9
    • Description of Packages – i.e. Drum, Box etc
    • The number of each type of package
    • The aggregate quantity of batteries (kg)

Emergency Information

The vehicle used to transport the dangerous goods, must carry the DG documentation, described above, and emergency information, as follows ,

  • Emergency documentation should include an Initial Emergency Response Guide, an Emergency Procedure Guide for the dangerous good, an Emergency Procedure Guide in relation to a vehicle fire.
  • Documentation can be kept in a prominent location in the the cabin.
  • See Chapter 11.2 – Emergency Information in ADGC for further details.

Conclusion

The ADGC’s regulations for transporting Used Lithium Batteries are complex and understanding the requirements can be difficult. I hope this article has helped you decipher the complexities of transporting used Lithium Batteries for disposal or recycling. If you have any questions, please feel free to email me at davidbush@batteryrescue.com.au

Future articles on the requirements for transporting used lithium batteries contained in equipment and for transporting damaged or defective Lithium batteries will follow shortly.

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