ST/SG/AC.10/C.3/2016/XX
United Nations / ST/SG/AC.10/C.3/2016/XX/ Secretariat / Distr.: General
30 March 2016
Original: English
Committee of Experts on the Transport of Dangerous Goods
and on the Globally Harmonized System of Classification
and Labelling of Chemicals
Sub-Committee of Experts on the Transport of Dangerous Goods
Forty-ninth session
Geneva, 27 June – 6 July 2016
Item XX of the provisional agenda
Miscellaneous proposals for amendments to the Model Regulations
on the Transport of Dangerous Goods: Transport of damaged/defective Lithium Batteries
Transport of damaged/defective Lithium Batteries
Transmitted by the expert of Recharge and OICA
Introduction
1. The transport of damaged/defective Lithium batteries is currently regulated in SP376. It allows two ways of transport, either P908/LP904 for the transport of damaged/defective lithium batteries, non-reactive under normal transport conditions (category A) or using a competent authority approval to transport damaged / defective lithium batteries possibly reactive under normal transport conditions (category B).
2. OICA members have examined several approvals given by competent authorities of different countries which indicate different transport solutions by using different packagings based on different testing and calculations methods. They recognised many similarities, summarized and proposed them as working document ST/SG/AC.10/C.3/2015/51 at the last ECOSOC Sub-Committee of Experts on the Transport of Dangerous Goods (TDG) meeting at Geneva in December 2015.
3. The outcome of the discussion at the Geneva meeting in December 2015 was to discuss this technical issue at the 3rd Informal Working Group Lithium Batteries and Manual of Tests and Criteria Meeting at Bordeaux for a technical review by the participating battery experts. The UN SCETG provided mandate to the Group to submit the outcome of this technical discussion at the Geneva meeting in June/July 2016.
4. The following points summarized the result of this technical discussion:
The proposal should describe all necessary conditions to select, qualify and apply a packaging for the transport of damaged and defective Li-batteries. This includes:
(a) The list of Identified hazards potentially linked to a battery thermal runaway event: the list in the SP376 is considered as complete,
(b) A list of prevention measures (aiming at inerting the batteries) in order to allow for application of the packaging according to P908/LP904. The following prevention measures are identified:
• [cooling (request for specification of minimum temperature at which the battery is inert, minimum time for cooling, applicable duration of transport, application of the conditions UN Model Regulations of 5.5.3 in case of dry ice usage)] this method has to be discussed at the UN IWG Meeting in Bordeaux,
• discharging (request a process verifying that all cells are discharged, [in the damaged battery condition]),
(c) For the case of the transport of damaged/defective, with possible reaction under normal transport conditions (category B batteries) without a competent authority approval, the list of the criteria regarding packaging performance:
• no hazardous temperature outside the packaging ( [100-200 °C]),
• no hazardous flame outside,
• no hazardous ejection of particles,
• no damage of the packaging e.g.,
• gas treatment (e.g. filter system, air circulation [as specified according UN Manual parag. 5.5.1] etc.).
(d) Methods for verification of these packaging criteria:
• The performance will be demonstrated by a test or by a calculation corresponding to the cell/battery type [as defined in UN Manual, i.e. 20% change in energy,…] in the condition of transport (e.g. SOC etc.)
• The calculation has to run on a verified model. The verification should be done under quality management system (it should consider all material properties, the worst failure modes, [be compared to a test result]).
• The test and verification report/result should be available on request (with precision of batteries name, number, weight, type, energy content, and packaging identification).
(e) Means for identification and traceability of the packaging qualification.
• [The packaging should be of a UN qualified type II (or I ?)]
• [The packaging should be identified by a reference allowing to check the qualification references].
Proposal
Based on this technical discussion the 3rd Informal Working Group Lithium Batteries and Manual of Tests and Criteria advised Recharge and OICA to submit a proposal and revise SP376 as follows ( changes underlined):
“Lithium ion cells or batteries and lithium metal cells or batteries identified as being
damaged or defective such that they do not conform to the type tested according to the
applicable provisions of the Manual of Tests and Criteria shall comply with the
requirements of this special provision.
For the purposes of this special provision, these may include, but are not limited to:
- Cells or batteries identified as being defective for safety reasons;
- Cells or batteries that have leaked or vented;
- Cells or batteries that cannot be diagnosed prior to transport; or
- Cells or batteries that have sustained physical or mechanical damage.
NOTE: In assessing a battery as damaged or defective, the type of battery and its
previous use and misuse shall be taken into account.
Cells and batteries shall be transported according to the provisions applicable to UN
3090, UN 3091, UN 3480 and UN 3481, except Special Provision 230 and as otherwise
stated in this special provision.
Packages shall be marked “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES” OR
“DAMAGED/DEFECTIVE LITHIUM METAL BATTERIES”, as applicable.
Cells and batteries, including those being inerted by means of [cooling] or discharging [or an alternative method], shall be packed in accordance with packing instructions P908 of 4.1.4.1 or LP904 of 4.1.4.3, as applicable. [If cooling is used for inertization there is the need for specification of minimum temperature at which the battery is inert, minimum time for cooling, and applicable duration of transport according the cooling method. In the case of dry ice being used parag.5.5.3 applies. this method has to be discussed at the UN IWG Meeting in Bordeaux] If discharging is used for inerting, there is the need for specification that all cells are completely discharged [in the damaged battery condition]. If an alternative method is used for inerting there is need for feasible evidence.
Cells and batteries liable to rapidly disassemble, dangerously react, produce a flame or a dangerous evolution of heat or a dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport shall not be transported except under conditions specified by the competent authority. These types of damaged/defective cells and batteries may also be transported without a competent authority approval, if:
1. the quality of the packaging is verified by one of the following methods:
• The performance shall be demonstrated by a test or by a calculation corresponding to the cell/battery type [as defined in UN Manual, i.e 20% change in energy,…] in the condition of transport (e.g. SOC etc.),
• The calculation has to run on a verified model. The test and calculation should be done under quality management system (it should consider all material properties, the worst failure modes, [be compared to a test result]),
• The test and calculation report/result should be available on request (with precision of batteries name, number, weight, type, energy content, and packaging identification),
2. the calculation of the packaging performance is done corresponding to a verified model and the verifiacation is done under a quality management system (which consider all material properties, the worst failure modes, [the comparison to a test result],
3. the test/verification report/result is available on request [and the cell and battery name, the cell and battery number, the weight, type, energy content of the cells and batteries and the packaging identification is listed as minimum],
4. a packaging is used, which meet the following criteria:
• no hazardous temperature outside the packaging ( 100-200 °C?),
• no hazardous flame outside,
• no hazardous ejection of particles,
• no damage of the packaging e.g.,
• gas treatment (e.g. filter system, air circulation [as specified according UN Model Regulation 5.5.1 etc.] etc.), and
5. the packaging performance is verified by the following points:
• [The packaging shall conform to the packaging group I [II?] performance level],
• [The packaging should be identified by a reference allowing to check the qualification references].
Conclusion
The working group propose the above change of SP376 for consideration by the UN SCETDG.
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