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RaineCaroline
Caroline Raine, Principle Consultant

Lithium batteries - changes to IATA regulations

17/11/2016

In a world where technology is continually advancing, we are seeing more and more products that contain lithium batteries flood the market. While this technology ultimately serves to make our lives easier, it also comes with added safety risks.

Over the past few months we have seen many reported incidents involving e-cigarettes catching fire while being charged and in people’s pockets and just last month the U.S. Department of Transportation (DOT), along with the Federal Aviation Administration (FAA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA), banned all Samsung Galaxy Note 7 smartphone devices from air transportation in the United States following widespread reports of units exploding. Occurrences such as these no doubt pose a number of risks for airlines and airports involved in the transportation cargo containing lithium batteries.

The transportation of lithium batteries is highly regulated and as such, The International Air Transport Association (IATA) have recently announced the changes coming in the 58th edition of its ‘Dangerous Goods Regulations’ publication.

The major change concerning lithium ion batteries is that those shipped outside of equipment (UN 3480) are now to be limited to cargo aircraft only. While this change was already in effect from April 1st 2016 this is only now being amended in IATA. Furthermore lithium ion batteries being transported at more than 30% of their rated charge capacity require special permission before they can be shipped. This is not the case should you be shipping lithium ion batteries with equipment or contained in equipment however (UN 3481).

The new Class 9 Lithium Battery hazard label has been added and it will come into effect from January 1st 2017. There will be a two-year transitional period where either the previously used Class 9 Miscellaneous Dangerous Goods hazard label or the new Class 9 Lithium Battery hazard label can be applied to packages containing lithium batteries. Additionally in this two year period the old lithium ion battery handling label will be replaced by the new lithium battery mark (IATA 58th edition figure 7.1.C). As with the new hazard label this will be in effect from January 1st 2017 and have a two year transitional period where the old handling label will still be accepted.

Instructions for employees responsible for the preparation of lithium ion battery packages has been expanded upon and there is now a paragraph detailing what needs to be established by employers to constitute “adequate instruction”. This will help reduce ambiguity and introduce a greater degree of consistency for how Section II packages should be prepared. Changes to A181 have also been made to more clearly describe the requirements for all packages that contain lithium batteries with equipment and contained within equipment.

Overall there have been several key changes to the IATA regulations regarding lithium batteries, most notably: lithium ion batteries are no longer permitted on commercial flights; they require new marks and labelling which will be in effect from January 1st, however, you will have two years to meet these requirements; and adequate instruction has been better defined as have the regulations regarding moving lithium batteries with or in equipment.

NCEC’s team of regulatory experts support companies across the world in overcoming the complex requirements of chemical regulations. One such way is through the provision of a guide entitled ‘Global Legal Standards for Emergency Telephone Numbers’. The guide outlines the global regulations concerning the provision of an emergency telephone number (including those stipulated by IATA) that require compliance for those transporting or supplying chemicals and is free to download, alongside many other useful resources, here.

If you have any questions concerning the transportation of hazardous cargo by air or realted to emergency telephone response, please do not hesitate to get in touch at caroline.raine@ricardo.com.

As part of its recent updates to poison centre legislation in Europe, the European Commission has launched a new online tool for chemical companies to generate Unique Formula Identifier (UFI) alphanumeric codes to include on all products classified for their health or physical effect in Europe.

 

 

 

 

 

Find out how UFI will impact the requirements on your business by contacting NCEC poison centre expert Larissa Silver at Larissa.silver@ricardo.com. Find out more about poison centre submission at the NCEC poison centre hub at http://the-ncec.com/poison-centres/


 

 

 

 

In September 2016, EU Member States voted in favour of the European Commission’s proposals to harmonise how companies submit product information to poison centres and other bodies appointed to receive information in the case of poisonings (http://the-ncec.com/blog/). The update to this legislation includes the introduction of a UFI to be included on product packaging or safety data sheets. This will come into force for mixtures intended for consumer use in 2020 and for professional and industrial mixtures as of 2021 and 2024 respectively.

 

 

 

 

 

The web based UFI generator tool enables companies to create and validate codes for their products, which is determined by the company’s VAT number and an internal reference code. The UFI is designed to allow easy identification of the product in a medical emergency and would be recognised across Member States.

 

 

It is up to individual Member States to interpret poison centre legislation at a national level, meaning the demands on companies handling hazardous goods can vary widely across Europe. This makes submission of products a costly and complex process, with companies risking fines or product removal in cases of noncompliance.

 

 

 

 

 

“The chemical industry is facing a number of changes from the update to poison centre legislation, but the launch of the new UFI tool so far in advance of when this comes into force shows that the Commission is giving businesses the time they need to adapt,” said Larissa Silver, Emergency Responder Supervisor and Chemical Regulatory Consulant. “However, poison centre registration still presents a significant administrative challenge to businesses operating in markets across Europe. That’s why we are supporting companies to analyse and determine each particular countries’ poison centre requirements to help them to ease the burden of submitting their products and avoid the penalty of non- compliance.”

 

 

 

 

 

Without additional clarification on how to implement poison center legislation, the level of information required by Member States on a product’s hazards, the registration process, the type of materials that need to be registered and the cost of compliance varies widely between Member States

 

 

 

 

 

NCEC’s regulatory experts support companies across the world in overcoming the complex requirements of poison centre registration and other regulations. It also provides a poison centre compliance pack covering the various regulatory demands in each country in Europe. Available as both a free download and a more comprehensive report, the pack provides clear, concise and easily applicable information for chemical companies to quickly identify their international obligations and avoid the risk of legal and financial repercussions from non-compliance. Download the poison centre resources at http://the-ncec.com/poison-centres/

 

 

 

 

 

For more information on the UFI tool, visit https://poisoncentres.echa.europa.eu/tools

 

 

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