{"operation":"document","citation":"PHMSA Guidance, Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling","title":"Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-05-17","effective_on":"2022-05-17","summary":"Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling Document Final-5-16-Lithium-Battery-Recycling-Safety-Advisory.pdf (351.77 KB) Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling PDF Issued Date: Tuesday, May 17, 2022","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-safety-advisory-notice-transportation-lithium-batteries-disposal-or-recycling-3bfe0ef8.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-safety-advisory-notice-transportation-lithium-batteries-disposal-or-recycling-3bfe0ef8.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-safety-advisory-notice-transportation-lithium-batteries-disposal-or-recycling-3bfe0ef8","source_url":"https://www.phmsa.dot.gov/training/hazmat/safety-advisory-notice-transportation-lithium-batteries-disposal-or-recycling","body":"Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling\n\nDocument\n\n Final-5-16-Lithium-Battery-Recycling-Safety-Advisory.pdf (351.77 KB)\n\n        Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling PDF\n\n          Issued Date: Tuesday, May 17, 2022\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSafety Advisory Notice for the Disposal and Recycling of\nLithium Batteries in Commercial Transportation\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nOffice of Hazardous Materials Safety\nWhy PHMSA Wrote this Safety Advisory Notice\nPHMSA wants to increase the public’s overall awareness about the dangers related to\nshipping lithium batteries for recycling or disposal. Lithium batteries — including both\nlithium metal and lithium ion batteries — can cause a fire, whether they are new, used,\ndefective, or damaged. Shippers and carriers need to take extra, and sometimes different,\nprecautions when shipping damaged, defective, or recalled lithium batteries, as opposed to\nnew and used lithium batteries or batteries of other chemistries. In addition to complying with\nthe general shipping requirements, anyone offering a lithium battery for commercial\ntransportation should also assess the potential fire hazards in transport. This safety advisory\noutlines regulatory requirements for proper and safe shipment in commercial transportation\nfor all lithium batteries intended for disposal or recycling and includes specific requirements\nfor lithium batteries that are damaged, defective, or have been recalled.\nDuring recent compliance inspections, PHMSA’s hazardous materials (HAZMAT)\ninvestigators routinely saw shippers and carriers improperly package and ship lithium\nbatteries for disposal or recycling. Such dangerous practices included packaging lithium\nbatteries in a way that did not prevent short circuits, mixing damaged lithium batteries with\n\n<<<PAGE 2>>>\n\nother batteries in the same packaging within shipments for disposal or recycling, and shipping\npallet loads of batteries in boxes and drums with inappropriate identification of the packages’\ncontents.\nThe contents of this safety advisory do not have the force and effect of law and are not\nmeant to bind the public in any way. The safety advisory is intended only to provide\ninformation to the public regarding existing requirements under the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171-180).\nWhat this Safety Advisory Notice Does\n• Summarizes the regulatory information needed for shipping lithium batteries in\ncommercial transportation for recycling and disposal.\n• Discusses the general dangers of shipping lithium batteries, what consumers should\ndo, and steps shippers and carriers need to take when disposing and recycling lithium\nbatteries and equipment/products containing lithium batteries.\n• Directs readers to a variety of additional resources for further information on\npreparing lithium batteries for shipment.\nThis Safety Advisory Notice is for Anyone Who\n• Prepares shipments for the disposal or recycling of lithium batteries.\n• Commercially transports used, damaged, defective, or recalled lithium batteries.\n• Disposes of lithium batteries.\n• Recycles lithium batteries.\n• Uses equipment/products that employ or contain lithium batteries.\n2\n\n<<<PAGE 3>>>\n\nFor Consumers\nWhat Consumers Should Do with Used, Damaged, Defective, or Recalled Lithium Batteries\nConsumers should take used lithium batteries to recycling or household hazardous\nwaste collection points. Consumers should NOT throw out lithium batteries in household\ngarbage or recycling bins.\nWhat Consumers Should Do with Recalled Equipment/Products\nIf a lithium battery or equipment/products containing a lithium battery has a recall notice,\nconsumers should follow the manufacturer’s safety instructions and disposal instructions. In\naddition, consumers should pay attention to any warnings from the manufacturer.\nFor Shippers and Carriers\nWhat Shippers and Carriers Need to Know About Lithium Battery Commercial\nTransportation Regulations\nThe safe shipment of lithium batteries in commercial transportation depends on\ncomplying with the HMR and using good judgment, regardless of quantity shipped. Lithium\nbatteries pose a fire hazard, even when no longer useful in powering consumer\nequipment/products. Shippers and carriers need to be careful to ensure lithium batteries do not\ncreate sparks or generate a dangerous quantity of heat, and are otherwise safe for transport\n[see § 173.21(c)]. The HMR in § 173.185(d) explains how to ship lithium batteries, including\nthose contained in or packed with equipment destined for disposal or recycling. Shipments of\ndamaged, defective, or recalled lithium batteries have even more restrictions than newly-\nmanufactured, used, or undamaged/properly functioning batteries because they are more\nlikely to ignite [see § 173.185(f)].\n3\n\n<<<PAGE 4>>>\n\nHow to Properly Ship Lithium Batteries for Disposal or Recycling\nShippers must package any lithium battery shipped for disposal or recycling in a\nmanner that prevents short circuiting and damage to the battery or its terminals in\ntransportation [see § 173.185(b)]. This may be achieved by packing each battery in a fully\nenclosed inner packaging made of electrically non-conductive material and separating the\nbatteries from each other and other electrically conductive material within the same package.\nAdditionally, lithium batteries must be packaged in a manner to prevent damage caused by\nshifting or placement of the batteries in the package.\nProtection against short circuiting, damage, and accidental activation are important\naspects of packaging. Common methods of protecting batteries against short circuits include\nplacing the cells or batteries in plastic bags or covering exposed terminals. Rather than\nprescribing the exact package configuration, PHMSA regulations use a performance standard\nthat allows shippers a degree of flexibility in how batteries are packed, provided the\nrequirements are met [see § 173.185(b)].\nInner packagings containing lithium batteries shipped for disposal or recycling may be\nplaced into a strong outer packaging instead of a specification outer packaging. A strong outer\npackaging is sturdy, durable, and constructed so that it will retain its contents under normal\nconditions of transportation. Normal conditions of transportation include changes in\ntemperature and humidity, shocks, loadings, and vibrations from package handling and\ntransport. Common examples of strong outer packagings are sturdy fiberboard, metal, or\nplastic boxes, drums, and gaylord boxes [see Part 173, Subpart B]. Note: for undamaged\nbatteries, multiple batteries may be placed into a single inner packaging, and multiple inner\n4\n\n<<<PAGE 5>>>\n\npackagings may be placed into the same strong outer packaging, provided the batteries remain\nprotected from short circuits and damage.\nFinally, lithium batteries that are damaged such that they have the potential to create\nsparks or generate a dangerous evolution of heat are subject to additional packaging and\nhazard communication requirements identified in § 173.185(f) and discussed in greater detail\nbelow.\nHow to Identify Damaged, Defective, or Recalled Lithium Batteries\nDamaged, defective, or recalled lithium batteries and equipment/products containing\nthese lithium batteries must follow the requirements in § 173.185(f). Shippers and carriers must\nseparately package damaged, defective, or recalled lithium batteries from other batteries shipped\nfor disposal or recycling. Damaged, defective, or recalled batteries have greater potential than\nundamaged lithium batteries to short circuit, to release heat, or even to cause a fire.\nConsumers can find information about recalls of lithium batteries and equipment/products\ncontaining them at the following resources:\n• www.recalls.gov\n• www.cpsc.gov/recalls\nTo determine whether a lithium battery is defective, damaged, or subject to a recall, a\nperson should rely on a technical expert with knowledge of the battery’s safety features and\ninformation from the equipment/product manufacturer. Some criteria to consider when assessing\nwhether a lithium battery is damaged or defective include, but are not limited to:\n• Batteries known to be defective or that have been recalled by their manufacturer.\n• Batteries that have leaked or vented.\n• Batteries suspected of being damaged but cannot be diagnosed.\n5\n\n<<<PAGE 6>>>\n\n• Batteries showing signs of physical or mechanical damage, such as:\no Swelling, relative to the same battery in its original state.\no Discoloration of the battery casing.\no Smell or corrosion.\no Loose or damaged wires.\no Known conditions of use or misuse.\nHow to Properly Ship Damaged, Defective, or Recalled Lithium Batteries\nDamaged, defective, or recalled lithium batteries may be shipped only by highway,\nrail, or vessel transportation. These batteries are strictly forbidden for commercial\ntransportation by aircraft [see § 173.185(f)]. Here are some details explaining how to properly\nship damaged, defective, and recalled lithium batteries:\n• Place the battery in an individual, non-metallic inner packaging that completely\nencloses the battery.\n• Surround the inner packaging with non-combustible, electrically non-conductive, and\nabsorbent cushioning material.\n• Place each inner packaging into its own specification outer packaging rated to the\nPacking Group I performance level. This means only one damaged, defective, or\nrecalled battery per inner packaging, and only one inner packaging per outer\npackaging.\n• Mark the outer packaging with “Damaged/defective” and identify the battery type.\nThe marking — reading “Damaged/defective lithium ion battery” or\n“Damaged/defective lithium metal battery” — must be in characters at least 12 mm\n6\n\n<<<PAGE 7>>>\n\n(0.47 inches) high. This marking is in addition to any other required package markings\nand labels discussed in the section immediately below.\nHow to Properly Mark and Label a Lithium Battery Package for Disposal or Recycling\nEach completed package containing lithium batteries or equipment/products must\ndisplay the appropriate markings and labels [see § 173.185].These markings and labels alert\ntransportation workers, including hazmat employees, throughout the supply chain of the\npresence of lithium batteries, of the need to handle them properly, and the measures to take in\nthe event of an emergency. PHMSA’s Lithium Battery Guide for Shippers contains more\ndetailed guidance on preparing packages of lithium batteries in various configurations and\nshipping scenarios.\nPackages containing lithium batteries must have proper hazard communication. In\ngeneral, packages containing lithium batteries shipped in accordance with the HMR require\nthe Class 9 lithium battery label as found in § 172.447 and depicted in Figure 1.\nFigure 1. Class 9 Lithium Battery Label\nSome shipments of smaller lithium batteries and equipment/products may qualify for\nlimited flexibility under § 173.185(c). Common equipment/products that may qualify for this\nprovision include cell phones, tablets, notebook computers, small children’s toys, and\n7\n\n<<<PAGE 8>>>\n\nhandheld power tools. Only certain shipments may qualify for this provision; for more details\non what shipments may qualify under this narrow provision, see PHMSA’s Lithium Battery\nGuide for Shippers.\nShipments that comply with the requirements of § 173.185(c) still require hazard\ncommunication, including the lithium battery mark depicted in Figure 2, with the\nappropriate UN identification number and a telephone number to call for additional\ninformation about the shipment [see § 185(c)(3)(i)].\nFigure 2. Lithium Battery Mark\nRequired Emergency Response Information\nPersons preparing shipments of hazardous materials — including lithium batteries —\ngenerally must include emergency response information on the shipping paper or on an\naccompanying separate document [see § 172.602]. The shipping paper must have an\nemergency response telephone number [see § 172.604]. This telephone number must include\nthe area code or international access code and be monitored at all times while the hazardous\nmaterial is in transportation or in storage incidental to transportation. The person monitoring\nthe emergency response telephone number must either: 1) be knowledgeable of the hazardous\nmaterial being shipped and have comprehensive emergency response and incident mitigation\n8\n\n<<<PAGE 9>>>\n\ninformation for that material, or 2) have immediate access to a person who possesses such\nknowledge and information. This means the person should be able to assist first responders at\nthe scene of an incident involving lithium batteries, with knowledge of fire or explosion\nhazards, protective clothing required, and evacuation distances. To best assist emergency\nresponders at the scene of the incident, emergency response information must include:\n• The basic description and technical name of the hazardous material.\no For example, “UN3480, Lithium ion batteries, 9” or “UN3090, Lithium\nmetal batteries, 9.”\n• Immediate hazards to health.\n• Risks of fire or explosion.\n• Immediate precautions to be taken in the event of an accident or incident.\n• Immediate methods for handling fires.\n• Initial methods for handling spills or leaks in the absence of fire.\n• Preliminary first aid measures.\nEmergency response information requirements may not be applicable to shippers and carriers\ntransporting qualifying shipments of “smaller” lithium batteries, per § 173.185(c).\nHAZMAT Training Requirements\nWho needs HAZMAT training?\nThe HMR impose training requirements that are generally applicable to any employee\nwho prepares, packages, offers, or transports lithium batteries for recycling or disposal [see\n§§ 172.700 through 172.704]. Training requirements may not be applicable to shippers and\ncarriers transporting qualifying shipments of “smaller” lithium batteries in accordance with\n§ 173.185(c).\n9\n\n<<<PAGE 10>>>\n\nWhich HAZMAT training is necessary?\nHAZMAT training [§ 172.704(a)] includes the following components:\n• General awareness/familiarization.\n• Function-specific training.\n• Safety.\n• Security awareness.\nA training program from another Federal or state agency that includes these four\nHAZMAT components can fulfill the HMR training requirements [§ 172.704(a)]. More\ninformation on training requirements is available from the PHMSA website:\nhttps://www.phmsa.dot.gov/training/hazmat/training-requirements-industry.\nWho is responsible for providing training?\nEach entity that employs individuals who prepare, package, offer, or transport lithium\nbatteries is responsible for:\n• Providing training for its employees who prepare, package, offer, or transport lithium\nbatteries (hazmat employees).\n• Testing its hazmat employees.\n• Certifying its hazmat employees’ training.\n• Developing, maintaining, and retaining its hazmat employees’ training records.\no Records must be kept for each hazmat employee for the following time frames:\n Three years from the date of the last training; and,\n 90 days after the hazmat employee has left the company.\n10\n\n<<<PAGE 11>>>\n\nSpecial Permits for Shipping Lithium Batteries\nPHMSA has issued special permits for packaging designs meant to handle damaged,\ndefective, or recalled batteries. A special permit allows a person to deviate from specific\nHMR requirements while maintaining an equivalent level of safety. A person applying for a\nspecial permit must demonstrate that the requested special permit achieves a level of safety at\nleast equal to that required by the regulatory provision from which they seek a deviation [see\n§ 107.105(d)]. A person who holds a special permit must comply with the special permit’s\nrequirements. The outside of each package authorized by a special permit is marked “DOT-\nSP” followed by the special permit number assigned. Anyone can search for the special\npermit number on the PHMSA special permits search page using the special permit number.\nEnvironmental Protection Agency Hazardous Waste Requirements\nLithium batteries may meet the definition of hazardous waste under the Resource\nConservation and Recovery Act if they exhibit a characteristic of hazardous waste such as\nignitability, reactivity, or toxicity when they are disposed. The Environmental Protection\nAgency recommends that lithium batteries be managed under the streamlined federal\n“universal waste” regulations in 40 CFR Part 273. Requirements include instructions on how\nto manage the waste, how to label containers, how long the waste can be accumulated on site,\nand where the waste can be sent, among others. More information on the proper management\nand disposal of lithium batteries is available from https://www.epa.gov/recycle/used-lithium-\nion-batteries.\n11\n\n<<<PAGE 12>>>\n\nAdditional Lithium Battery Resources from PHMSA\nPHMSA created additional resources on lithium battery regulations, which complement\nthis safety advisory notice. These resources include:\n• PHMSA’s website: https://www.phmsa.dot.gov/lithiumbatteries.\n• PHMSA’s Lithium Battery Guide for Shippers.\n• PHMSA’s recorded presentation on how to use the Lithium Battery Guide for\nShippers.\n• PHMSA’s Hazardous Materials Information Center\no Telephone number: 1-800-467-4922\no E-mail: infocntr@dot.gov\no The HAZMAT Info Center is staffed Monday through Friday, 9:00 a.m. to\n5:00 p.m. Eastern Time. If you contact the Info Center outside of normal\nbusiness hours, leave a message and someone will return your call the next\nbusiness day.\n• PHMSA’s Online CFR tool (oCFR).\no You can click on the link labeled “oCFR Tool” on the menu on the left under\n“Related Links.”\nIssued in Washington, D.C., on May 17, 2022.\nWilliam S. Schoonover,\nAssociate Administrator, Office of Hazardous Materials Safety\nPipeline and Hazardous Materials Safety Administration.\n12","truncated":false,"body_characters":17995}