From a cell phone to a vaccine cooling device, lithium batteries and lithium battery containing products are everywhere in our daily life. The transport of these products and batteries is a key point of potential risk and an ongoing focus for regulatory compliance – especially for air transport. These regulations continue to evolve due to the emergence of new lithium battery-containing products, real-life safety incidents involving the batteries and continued risk assessments. 


Several important lithium battery-related updates are included in the Dangerous Goods Panel of International Civil Aviation Organization (ICAO DGP) working group meetings and related working documents this year. To align with the recent update and addendums of ICAO Technical Instructions (TI) and the ICAO DGP discussions, the International Air Transport Association (IATA) recently issued Significant Changes and Amendments to the 63rd Edition (2022) of the IATA Dangerous Goods Regulations (DGR) to incorporate all amendments made by the IATA Dangerous Goods Board and includes addenda issued by ICAO to the content of the 2021–2022 edition of the ICAO Technical Instructions.  



This article summarizes and incorporates a series of updates discussed and documented by ICAO’s Dangerous Goods Panel, among which many are related to lithium batteries. Listed below are some major updates with interpretations. 


Regulatory update in accordance with DGR update and TI Working documents: 


1. Removal of Section II of Packing Instructions 965 (PI 965) and PI 968.  

A 3-month transition period until March 31, 2022, is allowed for shippers to adapt their logistics processes in accordance with Section IB of PI965 and PI968, as applicable.  


(Note: UL suggests liaising with your chosen airlines in order to seek clarification as to whether or not the airlines are enacting the transitional period.)  

Consequential amendments have been made to DGR 1.6.1, Special Provision A334, 7.1.5.5.1, Table 9.1.A and Table 9.5.A to reflect the deletion of Section II of PI 965 and PI 968. 


Interpretation:  

Section II of PI 965 and PI 968 are applied to lithium batteries stand alone: UN 3480 — Lithium - ion batteries and UN 3090 —Lithium metal batteries respectively.  


Section II was initially designed to facilitate the transportation of small batteries by excepting them from some of the usual requirements in the ICAO Technical Instructions, including some hazard communication requirements such as the Dangerous goods declaration form (DGD) to the operator. This made it challenging for operators to fulfil their safety risk assessment obligations. And if we have a closer look at the operator variances, we can find many operators / airlines would not accept PI 965 and PI 968 Section II lithium batteries stand alone. The number of operators doing so continues to grow. There are efforts being put into solutions for the low energy cells / batteries and the package standard SAE G27. However, it is expected to take quite some time, and until then removing Section II of PI 965 and PI 968 seems to be the solution which best address the issue.


2. Amendment of PI 966 and PI 969, to clarify the packing options 

    Packing Instruction 966 

  • The lithium cells or batteries are packed in a UN specification packaging, then placed with the equipment in a strong rigid outer packaging; or 

  • the cells or batteries are packed with the equipment in a UN specification packaging. 

  • The packing options in Section II have been deleted, as there is only one option available given that there is no requirement for UN specification packaging. 

Interpretation: 

Further clarification on the packing options. The key is to ensure lithium batteries shipped together with equipment are properly and safely packed.  

Excerption of the proposed changes: 

  •  Packing Instruction 966 (marking the potential update in ICAO Technical Instruction) 

  • Passenger and cargo aircraft for UN 3481 (packed with equipment) only 


I. SECTION I 

Each cell or battery must meet the provisions of 2;9.3.

I.2 Additional requirements 

  • Lithium - ion cells and batteries must be protected against short circuits. This includes protection against contact with conductive materials within the same packaging that could lead to a short circuit. 

  • Lithium - ion cells and batteries must: 

    • be placed in inner packagings that completely enclose the cell or battery, then placed in packaging of a type shown below that meets the Packing Group II performance requirements, then placed with the equipment in a strong, rigid outer packaging. 

    • be placed in inner packagings that completely enclose the cell or battery, then placed with the equipment in a packaging of a type shown below that meets the Packing Group II performance requirements. 

  • The equipment must be secured against movement within the outer packaging.

  • The number of cells or batteries in each package must not exceed the number required for the equipment’s operation, plus two spare sets. A “set” of cells or batteries is the number of individual cells or batteries that are required to power each piece of equipment. 

  • Batteries manufactured after 31 December 2011 must be marked with the Watt-hour rating on the outside case. 


II.2 Additional requirements 

  • Lithium - ion cells and batteries must be placed in inner packagings that completely enclose the cell or battery, then placed with the equipment in a strong rigid outer packaging. 

  • Cells and batteries must be protected against short circuits. This includes protection against contact with electrically conductive material within the same packaging that could lead to a short circuit. 

  • The equipment must be secured against movement within the outer packaging.

  • The number of cells or batteries in each package must not exceed the number required for the equipment’s operation, plus two spare sets. A “set” of cells or batteries is the number of individual cells or batteries that are required to power each piece of equipment. 


 

3.  Appendix I—A new appendix has been added to 63rd Edition of DGR to provide the detail of the changes that will come into effect as of 1 January 2023 based on the adoption of the changes arising from the 22nd revised edition of the UN Model Regulations as well as the changes that have been agreed to date by the ICAO Dangerous Goods Panel for inclusion into the 2023–2024 edition of the Technical Instructions.  


The lithium battery related changes include: 

  • Exclusion from the requirement for a test summary for equipment, including circuit boards, that contain only lithium button cells.

  • Change to the lithium battery handling mark to remove the requirement for a telephone number to be provided on the mark. There is a transition period until 31 December 2026 during which time the existing mark may continue to be used. 


4. Additional information from ICAO DGP Working Document on PI 967 and PI 970: 

Proposed amendments to P I967 and PI 970 of the Technical Instructions to include ‘Large equipment can 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’ in section I. 


Interpretation: 

This is to further clarify the option for the transport of large equipment as the previous version is a little confusing. The ground reason is that in real practice, it might be difficult to find a strong rigid outer package suitable for the large equipment and the equipment itself has provided equivalent protection.  


The amendments also include the clarifications that ‘Where multiple pieces of equipment are packed in the same outer packaging, each piece of equipment must be packed and protected against contact with other equipment so as to prevent damage.’


 


 


References: 

1. Significant changes and amendments to the 63rd edition (2022); 

2. ICAO Dangerous Goods Panel Working Group Meeting Documents (2021).