I was having a discussion with a colleague at DGTA about the use (or non-use) of the Class 9 battery pictogram placard for a CTU that functions as a giant battery. Why NOT use the 9A specimen with the battery pictogram?
DG Comparison UN3536 Lithium Batteries Installed in Cargo Transport Units.
Paul Horner is one of our directors at the DGTA. We were talking about the labeling/placarding requirements for UN3536 for Cargo Transport Units that essentially function as giant batteries. Basically the container is fitted with battery modules and managment systems that do not have to be marked and labeled inside the CTU.
But Paul raised the question about the placarding… why NOT use a placard with 9A specimen (the class 9 label with the battery pictogram on it). So I offered to put together a chart with what I thought were the current regulations regarding this.
Do you agree that this is the way the regs currently stand?
Placards are required by all modes however, no mention is made of the Lithium Battery Class 9 Label/Placard EXCEPT for IMDG which specifically forbids the use of format 9A. IMDG “5.3.1.1.2… For dangerous goods of class 9 the placard shall correspond to the label model No. 9 as in 5.2.2.2.2; label model No. 9A shall not be used for placarding purposes.
So here’s the chart I put together for this discussion as best I understand it. Is this accurate?
It would seem that the Class 9, 9A version with the battery pictogram would be better to describe (especially when viewed from a distance by first responders isolating the area around an incident). It would seem to be better to have the placard diagram clearly showing the battery pictogram.
Perhaps it’s not required because someone could put the UN number in the middle of a placard instead of on an orange plate? I am just guessing here.
Feel free to post a comment here or email me directly, and I’ll consolidate the feedback.
Here are some references for UN3536.
Thanks.
UN Orangebook No Packing Instructions, just the special provision below:
UN SP 389 This entry only applies to lithium ion batteries or lithium metal batteries installed in a cargo transport unit and designed only to provide power external to the cargo transport unit. The lithium batteries shall meet the requirements of 2.9.4 (a) to (g) and contain the necessary systems to prevent overcharge and over discharge between the batteries.
The batteries shall be securely attached to the interior structure of the cargo transport unit (e.g., by means of placement in racks, cabinets, etc.) in such a manner as to prevent short circuits, accidental operation, and significant movement relative to the cargo transport unit under the shocks, loadings and vibrations normally incident to transport. Dangerous goods necessary for the safe and proper operation of the cargo transport unit (e.g., fire extinguishing systems and air conditioning systems), shall be properly secured to or installed in the cargo transport unit and are not otherwise subject to these Regulations. Dangerous goods not necessary for the safe and proper operation of the cargo transport unit shall not be transported within the cargo transport unit.
The batteries inside the cargo transport unit are not subject to marking or labelling requirements. The cargo transport unit shall display the UN number in accordance with 5.3.2.1.2 and be placarded on two opposing sides in accordance with 5.3.1.1.2.
TDG Orangebook 5.3.1.1.2 Placards shall be affixed to the exterior surface of cargo transport units and bulk containers to provide a warning that the contents of the unit are dangerous goods and present hazards. Placards shall correspond to the primary hazard of the goods contained in the cargo transport unit and bulk container except that:
(a) Placards are not required on cargo transport units carrying any quantity of explosives of Division 1.4, Compatibility Group S; and
(b) Placards indicating the highest hazard only need be affixed on cargo transport units carrying substances and articles of more than one division in Class 1.
Placards shall be displayed on a background of contrasting colour, or shall have either a dotted or solid outer boundary line.
ADR 2025 SP 389
389 This entry only applies to lithium ion batteries or lithium metal batteries installed in a cargo transport unit and designed only to provide power external to the unit. The lithium batteries shall meet the provisions of 2.2.9.1.7.1 (a) to (g) and contain the necessary systems to prevent overcharge and over discharge between the batteries.
The batteries shall be securely attached to the interior structure of the cargo transport unit (e.g., by means of placement in racks, cabinets, etc.) in such a manner as to prevent short circuits, accidental operation, and significant movement relative to the cargo transport unit under the shocks, loadings and vibrations normally incident to carriage. Dangerous goods necessary for the safe and proper operation of the cargo transport unit (e.g., fire extinguishing systems and air conditioning systems), shall be properly secured to or installed in the cargo transport unit and are not otherwise subject to ADR. Dangerous goods not necessary for the safe and proper operation of the cargo transport unit shall not be carried within the cargo transport unit.
The batteries inside the cargo transport unit are not subject to marking or labelling requirements. Except as provided in 1.1.3.6, the cargo transport unit shall bear orange-coloured plates in accordance with 5.3.2.2 and placards in accordance with 5.3.1.1 on two opposing sides.
IMDG SP 389
This entry only applies to lithium ion batteries or lithium metal batteries installed in a cargo transport unit and designed only to provide power external to the cargo transport unit. The lithium batteries shall meet the requirements of 2.9.4.1 to .7 and contain the necessary systems to prevent overcharge and overdischarge between the batteries.
The batteries shall be securely attached to the interior structure of the cargo transport unit (e.g. by means of placement in racks, cabinets, etc.) in such a manner as to prevent short circuits, accidental operation, and significant movement relative to the cargo transport unit under the shocks, loadings and vibrations normally incident to transport. Dangerous goods necessary for the safe and proper operation of the cargo transport unit (e.g. fire-extinguishing systems and air-conditioning systems), shall be properly secured to or installed in the cargo transport unit and are not otherwise subject to this Code. Dangerous goods not necessary for the safe and proper operation of the cargo transport unit shall not be transported within the cargo transport unit.
The batteries inside the cargo transport unit are not subject to marking or labelling requirements. The cargo transport unit shall display the UN number in accordance with 5.3.2.1.2 and be placarded on two opposing sides in accordance with 5.3.1.1.2.
IMDG 5.3.1.1.2
Placards shall be affixed to the exterior surface of cargo transport units and bulk containers to provide a warning that the contents of the unit are dangerous goods and present hazards. Placards shall correspond to the primary hazard of the goods contained in the cargo transport unit and bulk container except that:
(c) placards are not required on cargo transport units carrying any quantity of explosives of division 1.4, compatibility group S; and
(d) placards indicating the highest hazard only need be affixed on cargo transport units carrying substances and articles of more than one division in class 1.
Placards shall be displayed on a background of contrasting colour, or shall have either a dotted or solid outer boundary line.
For dangerous goods of class 9 the placard shall correspond to the label model No. 9 as in 5.2.2.2.2; label model No. 9A shall not be used for placarding purposes.