BAM experience exchange packagings, QM program for the manufacture of lithium cells and batteries
We were invited to take part in the BAM experience exchange on packagings to present problematic cases from operational practice. Eva Glimsche took part for us and mentioned different topics.
One of them was the manufacture according to quality management program and the responsibility of the shipper to
request proof of it just like for the UN 38.3 Test. In our opinion this is a clear necessity because the requirement
regarding the existence of a QM program for the manufacture is listed in the regulatory texts as a prerequisite.
Dr. Anita Schmidt from the BAM commented on this topic as follows:
Citation:
From a practical point of view it would be the requirement for the manufacturer to fulfill this before the first transport
and later shippers wouldn´t have to inspect that.
Only the UN 38.3 Test Summary needs to be made available by the manufacturer or subsequent suppliers.
Citation End
The problem is the reference to the requirement for the manufacture according to QM program in road transport as
per ADR and in sea transport as per IMDG Code in the special provisions 188, 230, 310, 388 and 389 and
in air transport in all packing instructions for lithium cells and batteries. IATA had a proposal
in the 56. session of the
UN SCETDG (UN Subcommittee of experts on the transport of dangerous goods) to change
this. Several people present at that meeting confirmed orally that the majority of the
delegates was of the opinion that it is the sole responsibility of the manufacturer to
manufacture according to QM program. Yet the proposal itself with the wording posed was
not accepted. And in our opinion the explanation in the protocol is not sufficient.
You can have a look yourself. We´ve attached the proposal IATA ST/SG/AC.10/C.3/2020/40
(IATA) and the protocol of the 57. session of the UN SCETDG ST/SG/AC.10/C.3/114 that
took place from 30. November till 08. December 2020 to our newsletter. In the protocol the info
can be found right in the introduction and the status quo on page 13 und V.C.1.
can be found right in the introduction and the status quo on page 13 und V.C.1.
As we from Lithium Battery Service read this protocol another proposal is required that either proposes different text
to clearly describe the matter or as shown in the protocol that proposes an explanation in a newly added remark.
For us the best solution would be to change the text in 2.9.4.2 of the UN model regulations e.g. to read
The manufacturer must ensure that lithium cells and lithium batteries are manufactured under a quality management
program that includes
...
With this text it would be clear and the consignor/shipper could then refrain from having a confirmation on the
manufacturer according to QM program.
At the moment the term "quality management program" is used. We would in the course of this clarification adjust the
wording to "quality assurance program.
And with the text change of course all the references to the requirement of manufacture according to QM program in
road transport as per ADR and sea transport as per IMDG code in special provisions 188, 230, 310, 388 and 389 and
in air transport in all packing instructions are to be deleted.
