Many shipments of time and temperature sensitive products including food, pharmaceutical, medical devices, vaccines, and industrial chemicals such as chemical-mechanical planarization (CMP) slurries, adhesives, and sealants contain, or have attached to the package(s) and/or overpack(s) small battery-powered tracking devices / data loggers. Most of these devices use lithium metal or lithium ion cells or batteries as a power source.
Lithium cells and batteries are classified as dangerous goods and therefore must meet all of the applicable provisions of the Dangerous Goods Regulations (DGR) when shipped by air. This applies regardless of whether the lithium cells or batteries are shipped as cargo in their own right or whether the lithium cells or batteries are installed in a small device such as a data logger that is placed inside or attached to packages of cargo. In addition, to be permitted in transport all lithium cell and battery types must have passed the applicable tests set out in Subsection 38.3 of the UN Manual of Tests and Criteria.
The purpose of this document is to provide guidance on:
1. complying with provisions applicable to the transport by air of lithium batteries as set out in the DGR when lithium battery powered data loggers are contained in cargo; and
2. recommendations with respect to the use of battery-powered devices that are active during transport. The recommendations for active devices are taken from FAA Advisory Circular AC 21.91-1C, primarily the recommendations in Section 8 of the AC, which relate to active devices carried in the aircraft cargo compartment.
This document is based on the provisions set out in the 2017-2018 Edition of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions) and the 58th Edition of the IATA DGR, Section II of Packing Instructions (PI) 967 and PI 970.
The provisions of the DGR with respect to lithium batteries may also be found in the IATA Lithium Battery Shipping Guidelines (LBSG). In addition to the content from the DGR, the LBSG also has additional classification flowcharts and detailed packing and documentation examples for lithium batteries.
REQUIREMENTS FOR LITHIUM CELLS AND BATTERIES
The extent to which the lithium cells or batteries are regulated as dangerous goods depends on:
(a) the lithium metal content for lithium metal cells or batteries; or
(b) the Watt-hour (Wh) rating for lithium ion cells or batteries.
Fully Regulated Lithium Batteries
Lithium metal cells with a lithium metal content exceeding 1 g and lithium metal batteries with a lithium metal content exceeding 2 g.
Lithium ion cells with a Watt-hour rating exceeding 20 Wh and lithium ion batteries with a Watt-hour rating exceeding 100 Wh.
Devices that contain fully regulated lithium cells or batteries are subject to all of the provisions of the DGR, which includes:
(a) dangerous goods training. All persons involved in the preparation and shipping must have completed appropriate dangerous goods training and must attend recurrent dangerous goods training at intervals not exceeding 24 months;
(b) marks and labels on packages. All packages must be marked with the name and address of the shipper and consignee, the UN number and proper shipping name. Packages must also bear the Class 9 lithium battery hazard label, except that until 31 December 2018 the standard Class 9 miscellaneous hazard label may be used;
(c) documentation. The consignment must be correctly described on a Shipper’s Declaration for Dangerous Goods.
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