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If you ship batteries or products containing batteries, you’re likely aware of new regulations that took effect this year regarding lithium battery test summaries. Like many new policies, there can be a period of misinterpretation and confusion.
But there’s good news: CHEMTREC can make the compliance much easier for shipping or handling of these materials.
Let’s dive into exactly what these new regulations are and what they may mean for you.
Organizations including IATA, IMO, IMDG Code, ICAO Technical Instructions, and potentially other national and international dangerous goods regulations have mandated manufacturers and distributors of lithium cells, batteries, and equipment powered by lithium cells and batteries make available a test summary as specified in the UN Manual of Tests and Criteria, Sixth Revised Edition, Amend 1, Part III, sub-section 38.3, paragraph 38.3.5.
These summaries confirm the batteries or cells have been tested to meet the specified international safety requirements. The requirement applies to all lithium batteries or cells manufactured as of July 1, 2003, and is applicable to both cells and batteries, including those which are contained within a product.
These regulations don’t introduce any new testing. Fortunately, the new regulations only require providing information regarding testing already conducted by the manufacturer of the lithium battery or cell.
Furthermore, this information isn’t required to be attached to or even shipped with the batteries, but must only be available to anyone who requests it. The requirement applies to all lithium batteries or cells manufactured as of July 1, 2003, including those which are contained within a product.
For safety reasons, lithium batteries are subject to a series of design tests mandated by the UN (sub-section 38.3 of the UN Manual of Tests and Criteria). At this time, these regulations don’t introduce any new testing that must be done.
The new regulations are only about providing information regarding the testing already conducted by the manufacturer of lithium batteries or cells. The revised addition to the UN manual 38.3.5 now requires lithium battery test reports to be made available in the form of a test summary available to the supply chain. These summaries confirm the batteries have been tested to meet the referenced safety requirements.
One of the most important aspects of the test summary requirements is that the summaries be standardized and include the same relevant information. Per PHMSA guidance, a proper test summary must include:
*For more detailed analysis and guidance concerning the lithium battery test summary requirements, you can review IATA's official document.
This information isn’t required to be attached to or even shipped with the batteries, but must only be available to anyone who requests it.
It is acceptable for the provider to require the requestor to obtain a document electronically from a provider's website. The provider must ensure that the cell/battery/product has appropriate identifiers to align to the test summary.1
As lithium battery regulations become more complex, the supply chain will need more information about the batteries and cells they handle in order to maintain compliance.
These challenges include:
As lithium battery regulations become more complex, shippers in the supply chain need more information about the batteries they transport in order to maintain compliance. CHEMTREC has developed a lithium battery test summary document management system, CRITERION™, to assist with regulatory compliance.
CRITERION acts as a central source for test summary documents and provides customers with a full range of useful tools. A snapshot of these resources include:
For additional information on how CHEMTREC’s CRITERION lithium battery test summary document management system can work for you, contact us today.
CHEMTREC also offers training that meets the U.S. DOT training requirements for individuals who perform or direct the functions of packaging, marking, labeling, or loading packages containing lithium batteries for shipment by highway, rail, air or vessel.
Check out our Lithium Battery Training Course today to learn more.
1 “New UN Requirement For Lithium Battery Test Summaries.” U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration, https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/training/hazmat/71126/us-dot-testsummarybrochure.pdf
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