Interpretation on the change in P903 (2) ADR
There were several interpretations on the new wording in P903 (2).
In
ADR 2021, P903 (2) had the sentence "In addition for cells or batteries
with a gross mass of 12 kg or more employing a strong, impact resistant
outer casing..."
Now
one could get the idea that e.g. 4 lithium batteries with 3 kg gross
mass each (total: 12 kg) could also be handled under the P903 (2), which
is not what was intended.
For
clarity, the text has been changed in ADR 2023 (for a cell or a battery
with a gross mass of 12 kg or more). However it was not intended to
make a restriction on a single cell/battery for transport.
We asked Mrs Schwan from the Federal Ministry BMDV whether she shares our view and here is the her answer:
Hello Mr. Werny,
there
really seem to be different interpretations circulating here, we also
discussed this at the beginning of June at the exchange of experiences
of the control authorities. I share your interpretation: where only
really a single battery or device is allowed in the packaging (see LP
903) the word "single" is also used. The use of the singular in P 903(2)
was intended to clarify the gross mass reference. But each individual
battery must also have a strong impact resistand outer casing.
Best regards
Gudula Schwan
