Regulation on in + with finally agreed upon - Special Provision 390

Regulation on in + with finally agreed upon - Special Provision 390

Regulation on in + with finally agreed upon - Special Provision 390
With the new Special Provision 390 the UN Subcommittee of experts on the Transport of Dangerous Goods in their 53. session at the beginning of July has now finally also included the regulation used for years in air transport already through Special Provision 181 on the combination of lithium cells and lithium batteries contained in equipment with such packed with to be declared as „packed with equipment“.

The wording of the new Special Provision 390 in the report ST/SG/AC.10/C.3/106/Add.1 reads:
When a package contains a combination of lithium batteries contained in equipment and lithium batteries packed with equipment, the following requirements apply for the purposes of package marking and documentation:
(a) the package shall be marked „UN 3091 Lithium metal batteries packed with equipment“ or „UN 3481 Lithium ion batteries packed with equipment“, as appropriate. If a package contains both lithium ion batteries and lithium metal batteries packed with and contained in equipment, the package shall be marked as required for both battery types. However, button cell batteries installed in equipment (including circuit boards) need not be considered.
(b) the transport document shall indicate „UN 3091 Lithium metal batteries packed with equipment“ or „UN 3481 Lithium ion batteries packed with equipment“ angegeben werden, as appropriate. If a package contains both lithium metal batteries and lithium ion batteries packed with and contained in equipment, then the transport document shall indicate both „UN 3091 Lithium metal batteries packed with equipment“ and „UN 3481 Lithium ion batteries packed with equipment“.

The full text of the report of the session of the UN subcommittee of experts you can find under this link
https://www.unece.org/fileadmin/DAM/trans/danger/ST-SG-AC10-C3-106-Add1e.pdf

We are now eager to see whether this regulation will be implemented earlier through a multilateral agreement in ADR. Otherwise we´ll have to wait to use this in road transport and sea transport until 2021.

Number of lithium cells and lithium batteries that are packed with equipment
Yet neither in road nor in sea transport there is a limit to the number of lithium cells resp. lithium batteries that may be packed with equipment. Practically one could take one piece of equipment with one battery installed and pack it with one million batteries.

In air transport this is highly regulated. Here as „packed with“ only the number required to power the equipment plus two spare sets are allowed. For example: If a piece of equipment contains four cells. Then 12 cells may be packed with this equipment (4 as the number required to power the equipment + 4 + 4 as the two spare sets). Inside the package there are 16 cells now. 4 contained in equipment and 12 packed with the equipment.

This reduction in air transport was necessare because a lot of companies used the variety „packed with equipment“ when lithium ion cells and batteries of UN 3480 and lithium metal cells and batteries of UN 3090 were prohibited as cargo on passenger aircraft.

Checklist article for the variety in + with
Lithium-Battery-Service offers checklist articles for the shipping preparation of all transport varieties on all transport modes (road as per ADR, sea as per IMDG Code and air transport as per  ICAO TI/IATA DGR).

Each check list article contains the following tailored to the individual transport case:
- Checklist
- Marking (Example with UN number in 12 mm height of the letters and numbers and the proper shipping name if required plus the
  possiblity to enter addresses)
- Marking/Labelling (e.g. Lithium Battery Mark, Lithium Battery Label of Class 9 Lithium-Batterie-Markierung, Lithium Battery Class 9
  Hazard Label, Cargo Aircraft Only label)
- Documentation (e.g. transport document, IMO declaration, Shipper´s declaration, Air Waybill)
- if required also a checklist for the transport to the airport or seaport including vehicle control

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Just contact us under:
https://www.lithium-batterie-service.de/en/contact/consulting