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Confusion and Difficulties Associated With Implementation of the New Lithium Battery Provisions
By Frits Wybenga, Senior Technical Advisor

If you have any involvement in shipping lithium batteries or equipment containing lithium batteries, you now know that transporting them has become considerably more confusing since January 1, 2009.  These new requirements stem from amendments to the UN Model Regulations 15th revised edition and changes included in the 2009 – 2010 ICAO Technical Instructions (2009 IATA DGR).  To complicate matters, the recent DOT rulemaking, HM-215J/HM-224D, did not harmonize the HMR with the new international requirements, so that those transporting in the US and internationally are now faced with two sets of regulations.

Changes included in the 15th Edition of the UN Model Regulations
UN changes included in the 15th revised edition of the UN Model Regulation focused on new shipping names and Special Provision 188 which covers small cells and batteries that may be transported without being fully regulated as dangerous goods.  The changes were based on industry and PHMSA proposals. 

Based on industry proposals, lithium primary (metal) and lithium rechargeable (lithium ion) batteries were assigned separate shipping names as the hazards of the two types of batteries are different, particularly when it comes to firefighting. 

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