Changes to Lithium Battery Transportation Regulations
From 1st January 2020, all suppliers and manufacturers of lithium ion batteries, or products containing lithium ion batteries, must be able to provide additional critical safety information about these Products to other parties in the supply chain. This will take the form of a 38.3 Test Summary Report.
The new regulations, initially championed by the United Nations (UN), applies to all lithium batteries and cells manufactured after 30th June 2003 and equipment powered by those cells and batteries. The UN initiated this new regulation following tests on batteries and cells that replicated conditions in transport. These included impact, pressure and overcharge testing. This is an extension to current legislation, where a Safety Data Sheet (SDS) is required.
Companies transporting lithium ion batteries are expected to make use of technology to facilitate the availability of the test summary – there is no expectation for the shipper/distributor to provide paper copies with each consignment.
Information required in the test summary
Below is the breakdown of information required under the new legislation.
UN38.3 test report consists of following tests. – Altitude simulation – Thermal test – Vibration test – Shock test – External short circuit test – Overcharge test – Forced discharge test – Impact/Crush test . The tests are very useful specially for primary cells and batteries as well as secondary cells and batteries.
Greater transparency needed
There is still uncertainty as to whether this legislation applies to air shipments only from 1st January 2020 and sea/road shipments the year after, or whether the legislation is for all transport shipments from 1st January 2020.
The rules were published in 2018, but the requirement for adherence has not been highlighted sufficiently. The legislation states that the 38.3 Test Summary reports do not have to be available until 1st January 2020. In effect therefore, the industry must be compliant on the same day the reports legally need to be available.
Genuine Solutions has spent months sourcing relevant documentation and contacting the main regulatory bodies and organisations, including IATA, CAA, DGO, BExA and certain USA Transport Companies. There is a shared consensus across these organisations that information related to this legislation needs to be made more widely available and transparent.
Below is the breakdown of information required under the new legislation.
How to stay compliant
The best way to stay compliant with the new regulations is by maintaining communication with all the relevant bodies, such as IATA, CAA, BExA and transport companies. A key source of information often comes from attending relevant events and keeping up to date with industry news.
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Written by Stephen Harris, Supply Chain Director of Genuine Solutions.