The IATA exception for small batteries will be eliminated in 2022
by Jim Powell, President, Transportation Development Group (TDG) LLC
Mark your calendar for January 1, 2022 and March 31, 2022. Those are important dates for small lithium battery shippers. After March 31, 2022 there will be no more allowances for small lithium ion and lithium metal batteries packed under section II of the IATA packing instructions.
Here’s a table contrasting the 2021 regulations with the 2022 regulations.
|Example||2021||2022 (March 31)||Comment|
|2 AA Rechargeable Flashlight batteries||Excepted UN 3480 Instruction 965-II||Full Regulated. Instruction 965-IB||Full DG except that UN spec packaging isn’t needed.|
|1 loose lithium metal coin-cell||Excepted UN 3090 Instruction 968-II||Full Regulated. Instruction 965-IB||Full DG except that UN spec packaging isn’t needed.|
|Lithium Ion or Lithium Metal Battery Packed with or Installed in equipment||UN3481, UN3091 Instruction 966-II, 967-II, 969-II, 970-II||No Change||No change|
Here are the changes in the employer training/certification requirements.
|Example||2021||2022 (March 31)||Comment|
|2 AA Rechargeable Flashlight batteries||No Certification Needed. Only “adequate information”||Full HazMat/DG Certification||General Awareness, Safety, Security and Function Specific training required in 2022|
|1 loose lithium metal coin-cell||No Certification Needed. Only “adequate information”||Full HazMat/DG Certification||General Awareness, Safety, Security and Function Specific training required in 2022|
- Will I need to retrain my employees?
Maybe. If they are shipping by air and have not received full DG certification (see comments section above) in using Section I of packing instruction 965 or 968 then yes, they’ll need additional training.
- Do I need to train my handlers and forklift operators?
Same as above – if they were previously provided only “adequate information” related to Section II of 965 and 968, then yes they will need SOME additional training.
- If these new “IB” shipment are considered “full hazmat/DG” do I need to have UN specification packaging?
No, but you need everything else associated with fully regulated DG such as Class 9 Hazard Label (plus the lithium battery mark), a red and white hatched “Dangerous Goods Declaration” and an emergency phone number (that’s currently NOT required for Section II batteries).
- How does the emergency phone number for a Section IB battery different from the “Informational Contact” number of a Section II battery?
For a Section IB battery you will need a full 24 hour a day seven day a week emergency response phone number. Right now, for the small except the batteries under section II you don’t need an emergency phone number you only need an informational contact number which can be a customer service phone and it doesn’t have to be working 24 hours a day seven days a week. And this is an additional piece of information the informational phone number on the lithium battery mark will be eliminated. The DOT emergency response phone number on the paperwork will continue but there will be no phone number required for small excepted section 2 batteries.
This rule goes into effect January 1, 2022 and there is a three month phase-in. Where either the old for the new regulations can be used after March 31, 2022 on the new section IB packing instructions may be used for (small) loose lithium batteries.
Many small battery shippers are not fully trained under new Rules because of the change from Section II to Section IB.
|Air Cargo Carriers (and Their Shippers Prepare for Change) |
|IATA is removing exceptions in Packing Instruction 965-II and 968-II for small lithium-ion and lithium metal batteries, forcing shippers to use 965/968 IB.|
Cargo-Carriers had previously been allowed to accept these shipments, and some did (i.e. DHL). In 2022 there will be a phase-in period ending March 2022 and after that time these will not be allowed.
Here is the impact:
2022: (New) Full HazMat/DG training required (vs. the 2021 standard of “adequate instruction” )
2022 (New) Full DG Declaration form required
2022 (New) 24×7 Emergency Phone number on DGD (not just an information # on the label/marking)
2022 (New) Full Written Emergency Response Info
2022 (New) HazMat Label (Class 9) Required