Proposed Revision to Mailing Standards for the Transport of Lithium Batteries 1
Agenda Alignment of rules pertaining to lithium batteries Changes that will affect UN3480 Lithium-ion Batteries shipped separately Mode of transportation Quantity limitations Marking requirements Other changes for lithium-ion and lithium-metal batteries Marking requirements for UN3481 and UN3091 Documentation requirements New DOT Class 9 Lithium Battery Label Packaging requirements for all lithium batteries How to submit comments Questions 2
Alignment of Rules USPS is working to better align mailing standards for lithium batteries with PHMSA and ICAO regulations PHMSA changes are still proposed (pending) ICAO TI addenda 3 and 4 published in Jan and Feb 2016 effective April 2016 http://www.icao.int/safety/dangerousgoods/pages/default.aspx 3
Changes for UN3480 Mode of transportation Pub 52, section 349.21(f) Current: UN3480 batteries are allowed in surface or air Proposed: Align with UN3090 UN3480 batteries will be limited to surface transportation only Quantity Pub 52, section 349.222(d)(1) Current: UN3480 batteries are restricted to a maximum of 8 cells or 2 batteries per package Proposed: Align with UN3090 maximum of 5 pounds gross weight per package Note: No change for UN3481 Lithium-ion batteries packaged in or with equipment 4
Changes to UN3480 Marking Pub 52, section 349.222(a)(6) Current: mailpieces containing UN3480 batteries must bear markings that indicate that the package contains lithium-ion cells or batteries; that the package is to be handled with care, etc. Mailers may use a DOT-approved lithium battery handling label, in domestic air or surface transportation, to meet these marking requirements provided all required elements are included. Proposed: Mailpieces will be required to include a text marking AND a DOT-approved lithium battery handling mark as is currently required for UN3090 5
Additional Proposed Changes that affect other types of lithium batteries 6
Marking Markings for UN3481 and UN3091 (packaged in or with equipment) in air transportation: Eliminate the option to use a text marking instead of a DOT-approved lithium battery handling mark as described in Pub 52, sections 349.221(a)(6) and 349.222(a)(6) Mailers will be required to use a DOT-approved lithium battery handling mark for packages containing more than 4 cells installed in equipment, and all packages containing batteries packaged with equipment. 7
Documentation Document Pub 52, section 349.221(a)(7) and 349.222(a)(7) Current: mailpieces containing lithium batteries (and required to bear a lithium battery handling label) must also be accompanied by a document that indicates that the package contains lithium-ion cells or batteries; an indication that the package is to be handled with care, etc. Proposed: additional documentation requirement will be eliminated for all types of lithium batteries regardless of surface or air transportation 8
Labels ICAO has adopted a new combined Class 9 Lithium Battery label USPS capacity/quantity limitations for lithium batteries eliminate the need for this label in Postal networks. Added to the list of Prohibited labels in Pub 52, section 352.1 9
Packaging Packaging Pub 52, section 349.222(a)(5) Current: All packaging must meet all applicable requirements specified in 49 CFR 173.185 Proposed: Outer packaging of all mailpieces containing a lithium batteries must be rigid and of adequate size so the handling mark can be affixed on one side without the mark being folded. Exception for button-cell batteries packaged in equipment: padded bags or poly bags may be used when cells or batteries are afforded equivalent protection by the equipment in which they are contained. 10
Comment Period Deadline for FRN comments is March 24, 2017 Send comments to: By Mail: Manager, Product Classification U.S. Postal Service, 475 L Enfant Plaza SW, Room 4446, Washington, DC 20260-5015 By Email: ProductClassification@usps.gov Subject line: ATTN: Lithium Batteries. include the name and postal address of the commenter 11
Questions? 12