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Packaging Lithium Batteries per updated DOT Regulations

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By Amanda Mendonza Technical Services Representative

The Department of Transportation (DOT) has published an updated standard for safely packaging primary and secondary lithium batteries for shipment destined for disposal. There are two possible categories that your packaging requirements can fit under, and which category depends on whether you can answer yes to the following questions:

Is the battery manufactured with a vent for pressure release?

Is the battery manufactured with a fuse or mechanism to prevent the flow of current?

If you have a battery pack, is the battery manufactured with a mechanism to prevent the reverse of current flow?

A YES to these questions will put you directly under 49 CFR 173.185. This regulation explains:

• Package each battery so that there is no possibility of terminal-to-terminal interaction

• Outer packaging requirements are exempt, however, the container must be durable and uncompromised for safe transport

• There is no net battery weight limit beyond the weight rating of the outer packaging

• The shipping name must be UN3090, Lithium Battery, 9, pg II

• The package labeling required is the DOT Class 9 square-on-point (aka diamond) A NO to these questions or any uncertainty will allow you to utilize the Special Provision 188 or 189 (which provision is based on the lithium content of the battery) which explains:

• Package each battery so that there is no possibility of terminal-to-terminal interaction

• Outer packaging must be a DOT-rated container/drum

• Batteries must be tested according to the United Nations Manual of Tests and Criteria

• The net battery weight cannot exceed 66 pounds per outer container

• The shipping name is exempt and can be shipped as Non-Regulated Material

• Additional verbiage must be included on the outer container as well as on the shipping documents: o “Contains Lithium Batteries-If package is damaged, batteries must be quarantined, inspected and repacked”

• The outer container must also be labeled with: o “Forbidden from transport aboard passenger aircraft”

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