For the past several years, we have been made more aware than ever of the hazards associated with lithium batteries. For this reason, there have been long-standing requirements in the dangerous goods regulations that lithium cells and batteries being transported by any mode of transportation must be of a type proven to meet the criteria in Part III, Sub-section 38.3 of the UN Manual of Tests and Criteria. With the right online lithium batteries training, manufacturers of lithium cells and batteries know they must create and maintain a record of satisfactory completion of the required tests prior to offering the lithium cell or battery for transport.
Having said this, as with any product in as widespread use and demand as lithium batteries, knockoffs and shortcuts are always a worry. Exploding e-cigarettes, burning cellular phones, blazing hoverboards – we’ve all seen them, even with stringent manufacturing and testing requirements specified in the aforementioned regulations.
Making the Test Summary Available
As of January 1, 2020, however, the requirement of the most current UN Model regulations that “manufacturers and subsequent distributors of cells or batteries must make available the test summary as specified in the Manual of Tests and Criteria, Part III, Subsection 38.3, Paragraph 38.3.5” is effective in accordance with the international dangerous goods transportation regulations. IATA’s Lithium Battery Guidance Document further clarifies in the FAQ section that the test summary must be made available “upon request”. “Any individual or entity in the supply chain may request the test summary, e.g. regulator, consumer, or transport provider.”
There was certainly adequate notice disseminated of this January 2020 availability requirement, including guidance from regulatory agencies, trade associations, and other entities regarding ways for manufacturers and distributors to provide this availability, e.g. on a company’s website, etc. This is also something that the right online hazmat training would make them aware of.
My Take On the New Requirement
I personally cheered this new requirement, having long-standing empathy with shippers of lithium batteries and others in the supply chain who for years had been signing their names certifying compliance with the lithium battery testing requirements without truly having a reliable means to confirm this. When asked over the past several months by customers as to how they might obtain this test summary, I cheerily told them, “You can most likely get it from the product manufacturer’s website!”, after having myself done a quick search for “Panasonic UN 38.3 test report” and being immediately presented with a very efficient compilation of the test reports on the Panasonic website (Panasonic, if you’re reading, I’m forever a fan).
While there is no requirement for this test summary to be provided with a shipment of lithium batteries, it would not be out of scope for forwarders or operators, for example, to request it, and I have already heard of this happening. So when I was asked to write an article for this blog reinforcing the test summary availability that is now required as of January 1, I decided to do a quick, non-scientific test of my own just to reassure myself of how easy it would be for me to get a copy if I needed it! Hmmmph….
My Own Due Diligence
I started with a general search of phone manufacturers, since that seemed to be a simple place to begin. This turned into a surprisingly lengthy ordeal, but I had a teensy bit of success (Google has them on their website!). So I then expanded my tour of duty by researching who manufactures the batteries for the phones – creating a more lengthy ordeal for myself with even less success. One website directed me to their SDS lookup, which I hadn’t really even considered as we know an SDS is not required for articles such as lithium batteries. Disappointment again. While I did find a few SDSs and Spec Sheets providing blanket statements such as “ALL of our batteries are compliant with the requirements of the UN Manual of Tests and Criteria, 38.3”, I was unable to locate the specific test details required. I could only think that I was doing something terribly wrong.
Incredibly, I then had the brilliant idea to become a wholesale buyer of a product that contains lithium batteries, which I could then sell for a nifty profit in my off time from Bureau of Dangerous Goods. While chatting with a friendly company representative about my prospective large purchase, I casually inquired as to whether I could be provided with the UN Test Report Summary for the lithium batteries, as I may need it to meet regulatory requirements in my new business. My chat went immediately cold. Shortly I received “Sandra, this is a request I am unfamiliar with and would have to ask around for. What is the purpose of this summary report?”
I stood down when my exercise became stiflingly frustrating and I suddenly realized the incredible amount of on-the-clock time I had spent on what I thought was going to be a simple task (and I obviously won’t be leaving BDG anytime soon.)
I want to know your experiences! Do any of you have stories of success to share? We would love to know how this new requirement is actually shaping up out there in your world! In the meantime, if you have had an experience similar to mine, I feel your pain. Manufacturers and distributors – can you point us in the right direction? (And Panasonic, again, if you’re reading, I’m forever a fan.)
In the meantime, if you are looking for more information on this subject, be sure to check out IATA’s official 2020 Lithium Battery Guidance Document or the U.S. DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) Announcement for Lithium Battery Testing Requirements.
And to ensure you’re always remaining compliant, be sure to visit Hazmat University to take one of their latest online supplemental lithium batteries training courses. It will ensure you’re staying up-to-date with the latest requirements, guaranteeing that you’ll be safe, compliant, and confident in all things lithium batteries.
