Large lithium battery separated into individual lithium batteries with a maximum of 100 Wh using a switch
The question keeps coming up as to whether it is permissible to use
a special circuit to separate a large lithium battery for transport
into lots of small lithium batteries of max. 100 Wh in order to take
advantage of the simplifications of SP 188 in road transport according
to ADR, sea transport according to IMDG Code and part IB of VA 965 or
part II of VA 966 or VA 967.
We have asked the BMDV again and received the information from Ms Gudula Schwan, head of the G 16 - Transport of Dangerous Goods department, that it is still the case that this widespread practice is still unresolved, as there were divided opinions on the German document (https://unece.org/sites/default/files/2024-04/UN-SCETDG-64-INF09e.pdf) in the UN TDG subcommittee in June/July 2024 and no decision has been made so far.
If
your company uses this technology, we strongly recommend that you
approach the members of the UN TDG through your association to clarify
why your technology does not pose a greater risk during transport than
individual SV188 batteries. This way, you can work towards the inclusion
of a text in the UN Model Regulations that allows this form of
connection.
