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When Unregulated Goods Become Dangerous
An incident and German proposals to the UN Subcommittee bring to light an extreme condition a product may incur while enroute to its destination. The incident involved a shipment of AA Nickel Metal Hydride (NiMH) rechargeable batteries which when securely packed and protected against short circuiting are deemed not to be subject to the dangerous goods regulations. In this report Mr. Wybenga looks at the incident, normal conditions of transport, the operational dilemma, and what the plans are to avoid the problem in the future.
You may think that after evaluating your chemical product and finding that it meets none of the classification criteria for dangerous goods, that you can safely ship your product around the world with limited concern for safety. Of course, we all know that a material shown not to meet the criteria for dangerous goods may still pose some degree of hazard .It is incumbent on the shipper to properly package the product to ensure it will arrive at its destination intact. But an incident and German proposals to the UN Subcommittee bring to light an extreme condition you may not be aware your product could face while enroute to its destination. The incident involved a shipment of AA Nickel Metal Hydride (NiMH) rechargeable batteries which when securely packed and protected against short circuiting are deemed (see special provision 304 of the IMDG Code) not to be subject to the dangerous goods regulations. The incident illustrates the extreme temperature conditions to which your product might be exposed.

The Incident and the Investigation
On May 30, 2005 the modern German container vessel, Punjab Senator, while in the Bay of Bengal between Singapore and Sri Lanka suffered an explosion and fire involving two containers. The fire was eventually brought under control.
Most of the almost 1 million batteries on 36 pallets in the two containers remained intact but were no longer of commercial value. The vessel suffered relatively minor damage and was able to complete its scheduled route to Hamburg, Germany where the German government undertook an extensive evaluation of the incident.

The two containers were located adjacent to a heated fuel storage tank where the average wall temperature was reported to have been 70 to 80ºC, but containing fuel which may be maintained at 90 to 100 C. In the period leading up to the incident, the fuel temperature varied between 72º C and 88º C. Fuel heating was necessary to separate out fuel impurities and to pump the heavy fuel oil to the ship’s diesel propulsion system. The German investigators assumed that because of the close proximity to the fuel tank, the battery cargo was likely heated to a temperature of about 70º C. The fire originated in one of the two containers on the end closest to the fuel tank. NiMH batteries give off hydrogen when exposed to heat and it is theorized that hydrogen from the heated batteries met with an ignition source causing a fuel air explosion and subsequent fire.

The investigators carried out tests on batteries similar to those involved in the incident to ascertain how they behave under heated conditions. They found that below 60º C there was no adverse response from the batteries. When exposed to prolonged exposure to temperatures of 85 to 88 º C, the batteries self-heated ultimately leading to outgassing. The investigators speculated that temperatures below 85º C may also cause the batteries to react but further analysis would need to be done to confirm this opinion.

Normal Conditions of Transport
It would be pure speculation to try to conclude the exact temperature to which the batteries were heated onboard the M/V Punjab Senator. Based on the investigation, it would be safe to conclude it was somewhere between 70º C and 88º C. Even if the temperature were at the low end, one is bound to ask whether the dangerous goods regulations account for such a temperature.

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