Lithium Battery Training & Placarding Exceptions
By Terry Poland, DG Instructor, Transportation Development Group, © 2020
The US DOT always requires training for “hazmat employees” (anyone that works for a “hazmat employer” – if your job functions affect the safety of hazmat being shipped). But it depends on the lithium content or power level of lithium batteries. If you handle only small/excepted batteries, then you need only receive “adequate instructions” but not full certification. “Adequate instructions” basically means that you are fully trained to follow all the requirements outlined in the various hazmat/dangerous goods regulations – but you don’t have to fulfill the entire requirements in 49 CFR, 172.704, such as the complete “general awareness” and “security awareness” training.
However, if you handle large, fully regulated lithium batteries, they are just like any other hazmat – hazmat employees have to be certified under DOT regulations. By the way, generally, the threshold between excepted and fully regulated for lithium ion is 20 watt-hour/cell and 100 watt-hour/battery; lithium metal is 1 gram/cell and 2 grams/battery. Any batteries exceeding these limits are considered large, fully regulated (Class 9).
As for placarding trucks and containers, none is required for Class 9 materials, including lithium batteries, as long as they are shipped domestically (within the US or from a US origin to a US destination through a foreign country such as Canada to Alaska). However, it is important to note that other countries may require placarding for Class 9 materials, and it is the shipper’s responsibility to fulfill this. So you must first check to see if the country you are shipping to, as well as all transit points along the way, require placarding. To make this simpler, we suggest automatically placarding ocean containers that are departing the US for ALL foreign destinations. Remember, the general placarding rule allows you to placard for any hazardous material in any amount whether the placard is required or not.
For more information, see excerpts from 49 CFR below:
§172.504 — General Placarding Requirements
(f)(9) For Class 9, a CLASS 9 placard is not required for domestic transportation, including that portion of international transportation, defined in §171.8 of this subchapter, which occurs within the United States. However, a bulk packaging must be marked with the appropriate identification number on a CLASS 9 placard, an orange panel, or a white square-on-point display configuration as required by subpart D of this part. [172.504(f)(9)]
§171.8 — General Definitions
International transportation means transportation —
|(1)||Between any place in the United States and any place in a foreign country;|
|(2)||Between places in the United States through a foreign country; or|
|(3)||Between places in one or more foreign countries through the United States.|
See our full program catalog of lithium battery training courses.