Lithium-Ion and Regulations: Updating from a Storm Watch to a Storm Warning

Dr. Kerry Lanza, Palladium Energy

“Ladies and gentlemen, before takeoff, please stow your tray tables and put your seatbacks in their full upright and locked position. For your safety, please hand over your cell phones, laptops, MP3 players, cameras, DVD players and anything else with a lithium-ion battery in it.”  Lithium-ion batteries, the rechargeable energy source that has made our modern, on-the-go life possible, are under scrutiny. This time from the airline industry.

Why are lithium-ion batteries getting this focus from the airlines? In 2009, there were an estimated 3.3 billion lithium-ion batteries transported globally, an 83 percent increase over 2005 (PHMSA, 2009). The estimated failure rate of lithium-ion batteries is one failure per 10 million manufactured, and it is even lower in the transport environments. Despite the positive safety record associated with lithium-ion batteries,  the US Department of Transportation (DOT) is concerned about the potentially catastrophic consequences of a lithium-ion battery incident in the air.

Incidents in the News
Since lithium-ion batteries have started being used to power portable devices about 20 years ago, the number of airline passengers have increased 38 percent to 1.8 million people flying per day. During that same period, the Federal Aviation Administration (FAA) has documented 92 transport related incidents involving lithium-ion batteries and lithium-ion powered devices. Some of these incidents have received front page headlines. In February 2010, a United Parcel plane full of packages, including lithium-ion batteries, was engulfed in flames while landing in Philadelphia. While investigators have not reached a final ruling, they continue to review the melted shipment of lithium-ion batteries. In 2004, a plane carrying Vice Presidential candidate John Edwards made an emergency landing when a lithium-ion battery exploded in the hand of a television camera man. Just before take-off on a Lufthansa flight from Chicago to Munich in 2006, smoke began to bellow out from the overhead compartment above seat 2A. The crew grabbed fire extinguishers, opened the compartment and saw a carrying case in flames. After putting the fire out, they tossed the case out onto the ramp. Passengers watched as fire trucks and bomb squads roared onto the scene. But they found no terrorist device, just a charred laptop and a “six-pack” of melted lithium-ion batteries (Dade, 2006).

How to manage such a low probability and high consequence risk poses a great challenge to the DOT. The increasing demand for higher performance portable electronic devices that require smaller, more powerful batteries forces battery manufacturers to pack more active material into the limited volume of a battery case. Increased production of smaller, more powerful batteries creates a situation where batteries are more susceptible to an incident. Preventing an incident involves working with the battery industry to develop safety standards that are in line with the rapid change in demand for higher power batteries and developing effective practices to reduce risk. Before any new regulations can be enacted, it is prudent to look at the causes of failure, as well as the depth and breadth of current regulations.

Lithium-Ion Failure Analysis
The most likely causes of the lithium-ion incidents can be categorized into the following causes:
External Short Circuit: occurs when an exposed battery terminal contacts a metal object. When this happens, the battery will heat up causing ignition of the battery and any surrounding combustible materials.

Improper Use: generally regarded as improper charging and discharging associated with equipment use, inadvertent activation and overheating.

Non-Compliance: includes faulty battery design, false certification with regulatory and testing requirements, and improper packaging and handling, including counterfeit batteries.

Internal Short Circuit: caused by foreign matter introduced into the cell or battery during the manufacturing process. An internal short circuit can occur when a battery is physically damaged when dropped or punctured.

Current Regulatory Maze
For lithium-ion batteries and devices, a variety of agencies, regulations and certification bodies currently exist in a literal alphabet soup of alpha-numeric designations. There are US entities, European organizations, Japanese standards and individual industry standards and regulations. These standards, certifications and regulations have significantly improved lithium-ion battery and device safety. Some of these rules are just guidelines, while others are statutory (legal) requirements. Still others, while not mandatory, are necessary if a company wants to sell and market their products as being safe. Some of the significant organizations and rules include:

US/DOT and UN/DOT: In the US, 49 CFR defines shipping regulations for lithium-ion batteries. The United Nations (UN) defines regulations and testing requirements for safe packaging and shipping lithium-ion batteries globally.

UL: Underwriters Laboratories is an independent certification organization. Key standards for lithium-ion batteries include UL 1642 and UL 2054. With some overlap, these standards set safety guidelines for individual and replaceable Li-Ion batteries.

IEEE: The Institute for Electrical and Electronics Engineers have developed IEEE 1625 and 1725 standards. IEEE 1625 provides comprehensive system (battery and device) safety guidelines for laptop batteries. IEEE 1725 pertains to analogous system safety rules for cell phones.

CE: The European CE mark is a manufacturer’s self-declaration that the device meets requirements for European Union product safety.

CTIA: The Cellular Telephone Industry Association is an international group that certifies compliance to IEEE 1725.

IEC:  The International Electrotechnical Commission is a non-profit organization writing international safety standards. The IEC 62133 standard appears to be approaching acceptance and includes a very strict overcharge cell test.

Pending Regulations
So, what is the regulatory storm on the horizon? The US Department of Transportation (DOT) is proposing some lithium-ion battery pack packaging and shipping rules changes.

Basically, the changes will eliminate exceptions for small lithium battery packs. These changes, if promulgated, will make significant modifications to shipping regulations of lithium-ion battery packs and the devices containing these packs. Implications to the changes include:
• Small cells shipped via air will have to be classified as a Class 9 Hazardous Material
• These changes will force new labels and packaging requirements
• No grandfathering is allowed, so retesting of existing packs will be required
• Additional training will be needed for employees handling the packaging

The only group really supporting the changes is the airline pilots union; ironically, even the airlines and air-freight companies do not support the changes. The Rechargeable Battery Association has calculated first year costs to the industry for compliance to be more than $1.1 billion. Reoccurring costs will be in excess of $8.5 billion over 10 years. It is well documented that when problems have occurred with lithium batteries, it is because they were not packaged according to the existing laws and regulations.

Alternative Solutions
It may make more sense to see harmonization with international standards rather than total revocation of any exceptions. The International Civil Aviation Organization (ICAO) currently requires that all packaging containing lithium-ion batteries (less than 100 Whr) be packed in an inner packing, weigh no more than 10 kg, have an outer label of caution/handling, and the outer packing with its content being able to withstand 1.2 m drop. Only secondary lithium batteries >100 Whr should be shipped as Class 9.

Removal of exceptions from Class 9 shipping will only punish manufacturers who are committed to support the needs of their customers and adhere to all regulations to maintain safety.  It will take DOT several months to review the changes, plus they have to review the changes with other government agencies. Nevertheless, I suspect that the changes are coming and we will have to work with it. The Greek philosopher Epicurus said “The greater difficulty, the more glory in surmounting it. Skillful pilots gain their reputation from storms and tempests.”

Dr. Kerry Lanza is strategic marketing manager at Palladium Energy. Palladium has expertise in lithium-based technologies for battery packs that power portable and backup applications across various verticals including medical, data capture, data storage and consumer electronics.

Enterprise Lithium-ion Battery Action Plan. (2009). Retrieved from
Dade, C. (2006, August 15). Laptops Draw Scrutiny from Airline Officials. Wall Street Journal.

Contact Palladium Energy at

This article was printed in the November/December 2010 issue of Battery Power magazine.

Leave a Reply