The most controversial issue discussed in regard to transportation are Lithium Batteries. This, however, for a good reason: Lithium Batteries are the dangerous good which is most often transported undeclared or at least declared in a way not in compliance with applicable regulations.
The potential dangers of Lithium Batteries are high and is only exceeded by the amount of wrong, erroneous and misleading information in regard to this topic.
Because all Lithium Batteries - no matter whether of the Lithium - Metal type (UN 3090) or the Lithium - Ion (which include Lithium - Polymer) type (UN 3480) - must be considered a dangerous good, LOGAR offers specific training for Shippers of Lithium batteries.
We will assist you with the assessment of the test reports in accordance with Part III, subsection 38.3 of the UN Manual of Tests and Criteria, choosing “suitable” packaging and the determination, whether or not your batteries (or gadgets or equipment incorporating such batteries or packed with such batteries) may be excepted under section II of the applicable packing instruction or must be shipped as a fully regulated dangerous good in class 9.
Dangerous goods training from LOGAR will not only enable you to ship Lithium Batteries hassle - free in full compliance with applicable national and international regulatory requirements, but you will also be able to validate your operational procedures, structures and requirements beforehand and issue clear working guidelines and instructions to your staff.
Because the regulations and requirements applicable to Lithium Batteries invariably change every year, LOGAR recommends that even shippers who only ship so-called “excepted” Lithium Batteries best consider providing formal dangerous goods training in accordance with table 1.5.A of the IATA Dangerous Goods Regulations to all staff involved in the handling, shipping and packing of Lithium Batteries.
Although the regulations require for shippers of Lithium batteries which may be excepted under section II of their respective PI only that they provide “instructions commensurate with the responsibilities” to the relevant staff, experience shows that staff that has undergone formal training has a significantly higher ability to fully comply with the regulatory requirements applicable.
Increasingly manufacturers and distributors of Lithium cells and batteries provide so - called “Certificates of Conformity” to buyers of their products which intends to “prove” that the most basic requirement - proof of successful testing in accordance with Part III, subsection 38.3 of the UN Manual of Tests and Criteria - has been complied with.
Regrettably, such practice is also recommended by industry associations such as PRBA.
However, the German competent authority, the Federal Institute for Materials research (Bundesanstalt für Materialforschung, BAM) has ruled that at least in certain cases it is indispensable that shippers of Lithium Batteries obtain and assess the full UN test report before making shipping arrangements; as a minimum a certificate of conformity will have to meet stringent formal criteria and must be subjected to an evaluation of its plausibility.
A study undertaken in late 2013 by Transport Canada found that 78% of shippers of Lithium Batteries were not in compliance with the dangerous goods transport related regulatory requirements. These figures will certainly look not much different in Europe. In particular the total ban of Lithium metal batteries not either installed in or shipped with devices (UN 3090) effective January 1st, 2015 on passenger aircraft and the total ban of Lithium ion batteries not either installed in or shipped with devices (UN 3480) effective April 1st, 2016 on passenger aircraft proved to be challenging for shipper's and is straining their supply chains as well as substantially increases transport costs. The myriad of variations filed by states and especially airlines relating to the transport of Lithium batteries - even when of the type excepted under section II of the applicable PI or when installed in or packed with equipment - is adding aditional burdens on the shipper's - one reason more to rely on LOGAR's expertise in regard to damgerous goods transport compliance.
Out two-day training course "Lithium Batteries" covers both the ADR mode (including the transport of prototypical Lithium batteries in accordance with Special Provision 310 ADR or damaged Lithium cells and batteries in accordance with SP 376 ADR) as well as the ICAO / IATA air transport requirements with a particular focus on the additional requirements when transported to, from or through the US under 49 CFR and other state and operator variations. Furthermore, another focus is on the controversial requirement applicable since April 1st, 2016 that Lithium - Ion - Batteries (UN 3480) when shipped as such (e.g. when not installed in or packed with equipment) must be shipped at a State of Charge (SoC) of < 30% and the implications resulting from this requirement for the shipper.