This summer, specialists across the industry came together for our webinar,Managing Test Summary Requirements Through Knowledge & Innovation, where we covered information on lithium battery test summary management and the new requirements under UN 38.3. Beyond sharing information, the panelists answered participants toughest questions and discussed how companies and industry partners worldwide are confronting the challenges involved and finding solutions through innovation. Here are some questions asked during the live event, which may also be applicable to your organization:
- Why was the test summary regulatory requirement adopted? It was intended as means to avoid having airlines and freight forwarders request Safety Data Sheets (SDS) and UN 38.3 test reports. To address this issue, some lithium battery and device manufacturers provided product information sheets with this information, although, this was not a wide-spread practice. The UN Model Regulations now have a requirement for lithium battery manufacturers and distributors to make available lithium battery test summaries (TS) using a standardized set of elements. Listen to our webinar recording to hear more about how this requirement came into effect.
- Is the TS a required shipping document? It is not intended to be a shipping document, but some freight forwarders are requesting it. Even though it is not required, they may hold up your shipment until you produce a TS; best practice would be to provide it upon request to avoid delay in shipment. It’s important to note suppliers must have them for international shipments, by air and sea, based on ICAO TI (technical instructions) and IMDG Code.
- How does it affect organizations that do not manufacture or sell lithium batteries or products containing lithium batteries? Whether your company is shipping lithium batteries or products containing lithium batteries, you are going to be subject to the test summary requirement. It is possible for your freight forwarder to stop that shipment until you can produce a TS. Unfortunately, the burden is on you to reach out to the original equipment or battery manufacturer to get that test summary. This is an example of how your organization can leverage CHMETREC’s CRITERION service to help obtain the associated test summary.
- How does the requirement affect sending batteries for recycling? A lithium cell or battery, including a lithium cell or battery contained in equipment, that is transported by motor vehicle to a permitted storage facility or disposal site, or for purposes of recycling, is excepted from the testing and record keeping requirements. See 173.185 paragraph (a) and the UN performance packaging requirements in paragraphs (b)(3)(ii), (b)(3)(iii) and (b)(6) of this section, when packed in a strong outer packaging conforming to the applicable requirements of subpart B of this part. A lithium cell or battery that meets the size, packaging, and hazard communication conditions in paragraph (c)(1)-(3) of this section is excepted from subparts C through H of part 172 of this subchapter.
- How do you see the requirement evolving? The UN Dangerous Goods Sub-Committee approved exemption from test summary for button cells installed in equipment and the elimination of signature requirement. These changes will go into effect January 2023. Anticipated future work on test summary by UN Dangerous Goods Subcommittee include changes to applicable compliance date (i.e., batteries manufactured after 2003 subject to test summary), clarification of what it means to “make available” the test summary, and a new statement that clarifies OEMs should not be held responsible for their lithium batteries if they have been “refurbished.”
- Does CHEMTREC have a library of test summaries to date? Yes, CHEMTREC has developed a program called CRITERION where we help customers, obtain, maintain, and distribute lithium battery test summary reports. Learn more about CRITERION.
- How does the CRITERION system help identify battery TS? The CRITERION system provides an easy search function based on whether the information you are looking for is either a product with a battery inside or a battery. Since products can have multiple TS’s, the product manufacturers can indicate the batteries associated with the product by linking multiple battery TS together. This allows search of the stand-alone battery, that can then be associated with a product, and search of a product (i.e., mobile phones) with one or more battery TS.
- My organization is a product manufacturer, how do I know I am linking the correct battery TS? While the CRITERION system cannot determine if the battery TS is valid and/or meets the necessary regulatory requirements, the system provides insight into where the document came from, so you can make a more informed decision as to whether you would like to use a particular document or not.
- Ensuring I have all necessary batteries and products listed in my library is very important. Is the CRITERION system able to provide detailed reports for this information? Yes, you can request a copy of a detailed report for all products listed within your library. This includes a report indicating which battery records are associated to each product.
- If there is a product or battery that I need listed, but is not currently in the CRITERION master library, what is the best way to request CHEMTREC to source the information on behalf of my organization? There are multiple ways in which this can be accomplished. If you are an existing customer, and enrolled in the sourcing service, you may login to the CRITERION system and fill out a request form. When filling out this request, you will need to indicate whether it is for a product (i.e. cell phone) or a specific battery, with as much detail as possible.
Watch the webinar recording!
The full webinar recording is available on demand through CHEMTREC’s Learning Academy.
The information contained in this presentation is provided for general information purposes only and must not be relied on as specific advise in connection with any decisions you may make. No representations or warranties, express or implied are made by The American Chemistry Council and its CHEMTREC division nor any company or companies presenting these materials and their affiliates are not liable for any action you may take as a result of you relying on such material or for any loss or damage suffered by you as a result of this action. Furthermore, these materials do not in any way constitute an offer to provide specific services.