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Archive for the ‘DOT/UN’ Category

New Regulation for Lithium Battery Manufacturers and Distributors

August 3rd, 2019 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Safety, Skolnik Newsletter

There is a new requirement for lithium cells and batteries that has the potential of creating a huge wave within the dangerous goods community within the next 2 years. This requirement is known as the “UN 38.3.5 Lithium cell and battery summary” that can be found in the “Recommendations on the Transport of Dangerous Goods Modal Regulations Volume II twentieth revised edition”. In paragraph 38.3.5 it states, “the following test summary shall be made available”. The question becomes “made available to whom”? The intent of the paragraph was meant to mean that the 38.3 test summary be made available by manufacturers and subsequent distributors of lithium cells and batteries to regulatory enforcements officials. The test summary refers to the UN 38.3 testing that is conducted on all new lithium batteries.

The testing on these batteries ensures that batteries are in a condition for transport that ensures that the batteries travel safely through the logistics chain. The testing and subsequent documentation also ensures that counterfeit batteries that have not been tested stay out of the logistics chain. According to 38.3.5 the information that “shall” be provided in the test summary include:

  • Name of cell, battery or product manufacturer, as applicable;
  • Cell, battery or product manufacturers contact information to include address, phone number, email address and website for more information
  • Name of test laboratory to include address, phone number, email address and website for more information
  • A unique test report identification number
  • Date of test report
  • Description of cell or battery to include at a minimum;
    • Lithium ion or lithium metal cell or battery
    • Mass;
    • Watt-hour rating or lithium content
    • Physical description of the cell/battery; and
    • Model numbers
    • List of tests conducted and results (i.e., pass/fail)
  • Reference to the assembled battery or testing requirements, if applicable (i.e. 38.3.3 (f) and 38.3.3 (g));
  • Reference to the revised edition of the Manual of Tests and Criteria used and to amendments thereto, if any; and
  • Signature with name and title of signatory as an indication of the validity of information provided. Lithium Cell and Battery Test Summary Challenge with change.

As with most changes that occur with the regulations, the challenge will be communicating the correct application of this rule to shippers, freight forwarders to ensure that there is an understanding that this document is not necessary for transport. Comprehensive and consistent training is an easy way to ensure that the requirement for this document is understood and implemented correctly. Remember, the document is meant to be made available to enforcement officials that need to refer to it should there be an incident involving a lithium battery shipment.

Skolnik’s 49CFR Cheat Sheet Helps to Quickly Locate Packaging References

July 23rd, 2019 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

Not sure where to begin a search for a packaging reference in 49CFR? The CFR (Code of Federal Regulations) is the Hazardous Materials shipping bible. In Title 49, there are definitions, classifications, regulations and a host of specific requirements set forth by the US DOT regarding the safe transport of hazardous materials by air, rail, water or road. Subtitle B of Chapter 1 refers to the Research and Special Programs Administration, with Subchapters A — C targeting Hazardous Materials Transportation Pipeline Safety, Oil Transportation, and Hazardous Materials Regulations. These subchapters are divided into Parts 171-180 with Subparts, Sections, Paragraphs and Subparagraphs. Part 178 addresses Hazardous Materials Packaging Specifications.

Finding a particular reference to a regulatory question can be difficult. For several years, Skolnik has been developing a CFR Cheat-Sheet of specific paragraphs that speak to common questions regarding UN (United Nations) packagings. A part of the Skolnik web site, the CFR Cheat-Sheet lists, and links, to about 50 packaging references and the exact paragraph that explains the regulatory requirement. The Cheat-Sheet primarily focuses on Section 49 of the CFR, and requirements mostly applicable to steel and plastic drums of all sizes.

US DOT Embraces Auto Driving

June 25th, 2019 by Howard Skolnik

Filed under: DOT/UN, Safety, Skolnik Newsletter

The United States surface transportation system provides tremendous mobility benefits, including widespread access to jobs, goods, and services. It also connects many remote regions of the country to the larger economy. These benefits, however, come with significant safety challenges, as motor vehicle crashes remain a leading cause of death, with an estimated 37,133 lives lost on U.S. roads in 2017. Traditional safety programs and policies have made road travel significantly safer than in the past, but there is much room to improve traffic fatality and injury rates.

The U.S. Department of Transportation is taking active steps to prepare for the future by engaging with new technologies to ensure safety without hampering innovation. With the release of Automated Driving Systems 2.0: A Vision for Safety, the Department provided voluntary guidance to industry, as well as technical assistance and best practices to States, offering a path forward for the safe testing and integration of automated driving systems. The Department also bolstered its engagement with the automotive industry, technology companies, ii PREPARING FOR THE FUTURE OF TRANSPORTATION and other key transportation stakeholders and innovators to continue to develop a policy framework that facilitates the safe integration of this technology into our transportation systems. Preparing for the Future of Transportation: Automated Vehicles 3.0 (AV 3.0) is another milestone in the Department’s development of a flexible, responsible approach to a framework for multimodal automation. It introduces guiding principles and describes the Department’s strategy to address existing barriers to safety innovation and progress. It also communicates the Department’s agenda to the public and stakeholders on important policy issues, and identifies opportunities for cross-modal collaboration.

Read the full article here

PHMSA Announces Advisory Committee on Transportation of Lithium Batteries

June 18th, 2019 by Howard Skolnik

Filed under: DOT/UN, HazMat, Safety, Skolnik Newsletter

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) announced on May 9th, 2019, that it is soliciting nominees for a new Lithium Battery Safety Advisory Committee, in accordance with Section 333(d) of the FAA Reauthorization Act of 2018. “The Department is seeking experts from diverse technical and transportation backgrounds to evaluate safety improvements for the transportation of lithium batteries,” said U.S. Secretary of Transportation Elaine L. Chao.

The Committee will provide a forum for the Department to solicit stakeholder input to continually strengthen the safety of multimodal lithium battery transportation. PHMSA is seeking nominations from across the transportation and manufacturing industries to participate. Further, the Committee will advise the Department on developing policy positions for international forums and on how to increase awareness of the importance of lithium battery safety requirements. The Committee will submit their findings to both the Secretary and Congress. For further information, see the announcement as posted to the Federal Register. Nominations must be submitted within 21 days of the Federal Register publication date.