[ID] => 9548
[post_author] => 34
[post_date] => 2018-05-08 08:27:18
[post_date_gmt] => 2018-05-08 07:27:18
[post_content] => A new requirement relating to the transport of lithium cells and batteries has the potential to create confusion in the dangerous goods community over the coming two years. The requirement, which involves the lithium cell and battery test summary, appears in the sixth revised edition of the Manual of Tests and Criteria as a new paragraph 38.3.5, following major reconfiguration of the testing procedures contained in section 38.3.
The intent of section 38.3 is to ensure that cells and batteries are properly tested so that they will travel safely through the logistics chain. The testing and subsequent documentation also ensures that counterfeit batteries that have not been tested – and that are identified as being responsible for fires during transport – are kept out of the supply chain.
The new 38.3.5 requires completion of a test summary, which must include:
- The name of the manufacturers of the cell, battery or product, as applicable
- Contact details for that manufacturing, including address, phone number, email address and website for more information
- Name of the test laboratory, with contact details as above
- A unique test report identification number
- The date the test report was completed
- Description of the cell or battery, including at a minimum:
- Whether it is lithium ion or lithium metal,
- Its mass,
- The Watt-hour rating or lithium content,
- A physical description, and
- Model number(s).
- A list of the tests conducted and their results (i.e. pass/fail)
- Reference to assembled battery testing requirements, if applicable (i.e. 38.3.3(f) and (g))
- Reference to the revised edition of the Manual of Tests and Criteria used and to amendments thereto, if any, and
- A signature with the name and title of the signatory as an indication that the information provided is valid.
Paragraph 38.3.5 also states that, “The following test summary shall be made available”. The 20th revised edition of the UN Recommendations on the Transport of Dangerous Goods includes a similar requirement at 2.9.4(g): “Manufacturers and subsequent distributors of cells or batteries shall make available the test summary…”.
This raises the question: make available to whom? Paragraph 2.9.4(e)(iv) says that “Test data shall be kept and made available to the competent authority upon request” and the test summary must also be available to any enforcement officials that need to refer to it in the event of an incident involving a lithium battery shipment.
That suggests that the test summary itself will have to be passed on from the manufacturer, importer or supplier along the supply chain to initial and subsequent distributors, freight forwarders and buyers – the same requirement will apply to cells and batteries that are included in or packed with equipment, and the logistics chain of those goods, down to the retail level.
As the requirement stands, there is no need for the document to be available to carriers. As such, it cannot be seen as part of the transport document. But could that change? At some point, carriers’ insurance companies may decide that they need confirmation that the batteries being carried by the insured’s vehicles have been tested according to section 38.3 and have passed the relevant tests. The document could also be demanded by third-party logistics companies engaged in contract packing and shipping activities on behalf of their customers.
As with most regulatory changes, the key to preparedness is comprehensive and consistent training. Only that way can organisations ensure that the requirement is understood and implemented correctly, and that the requirement is communicated properly to other parties further along the logistics chain.
Organisations need to start planning for training and implementation now. This planning process will need to include an audit of current battery inventories and manufacturers so that a document control system can be implemented. The planning process must also make sure that those responsible for procuring cells and batteries know that they must receive the test document along with the cells or batteries being purchased.
Once identified and received, the test summary documents should be sent to those responsible for record retention for other dangerous goods-related documentation to ensure the information is readily available on request. As of now, there is no record retention requirement for this document, which means that the document should be available at all times. Lastly, training and implementation should involve an understanding of what the document is and when it is required to be supplied to the officials requesting it.
As with all the other provisions for lithium batteries over the years, this requirement for the test summary is sure to create some confusion and misapplication over the course between now and the mandatory date of January 2020. That is why it is imperative to ensure that correct and timely information is available to all stakeholders involved in the safe and legal transport of lithium cells and batteries.
*Michael Bowen is president of Bureau of Dangerous Goods Ltd, a leading producer of training, technology and consulting for the dangerous goods industry; he is a certified Dangerous Goods Safety Adviser (DGSA) and IATA Dangerous Goods Instructor. He regularly teaches and/or speaks at various industry trade associations such as COSTHA, DGAC and IATA and was the leading content developer for Hazmat University. He urges his team and clients to embrace and promote a culture of compliance for dangerous goods. For more information go to www.BureauDG.com.
[post_title] => Batteries: Testing, testing
[post_status] => publish
[comment_status] => open
[ping_status] => open
[post_name] => batteries-testing-testing
[post_modified] => 2018-05-08 08:27:18
[post_modified_gmt] => 2018-05-08 07:27:18
[post_parent] => 0
[guid] => https://www.hcblive.com/?p=9548
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[post_type] => post
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Batteries: Testing, testing
All those shipping and handling lithium batteries have a new duty - Michael Bowen* explains that the test summary requirements mean for industry