Li-Ion Battery Shipping, Regulations and Refurbishment

Shannon Given, Editor, Battery Power Online

April 24, 2018 | At the 35th International Battery Seminar last month there were presentations of new battery technologies, exploration of battery chemistries, and assessments of the battery market. But everything wasn’t focused on the new. Attendees and speakers also dug into what to do with the old.

Cynthia Millsaps, President and CEO of Energy Assurance gave a great overview of shipping regulations for Li-ion batteries and power banks. With a quick explanation of definitions on what is considered “portable”—in particular with regards to IEC 62133, IEC 60950-1, and IEC 60601-1,—Millsaps explained the shipping regulations for UN 38.3, whereas Li-ion cells and batteries are considered a Dangerous Good and/or a Hazardous Material, which may be shipped alone, shipped with equipment, or shipped contained in equipment. Shipping regulations for IEC 62281 have a couple differences including the addition of component-cell testing and a package drop testing.

UN 38.3 battery testing requires eight or 16 batteries and the cell must be tested separately, include at least 50x cycling and sequential test, performed in five to seven weeks.

The shipping regulations need to be considered on both the national and regional level, as well the each carrier, aircraft, and vessel, in addition to packaging, markings, labels, and documentation.

George Kerchner, Executive Director with PRBA, The Rechargeable Battery Association, outlined the complexities of shipping Lithium batteries, and the importance of regulatory conformity. Kerchner recalled a railway incident in Houston, Texas, in April 2017. Thirty-six drums of used Li-ion batteries made up an undeclared DOT haz mat / EPA waste shipment. A fire broke out and because the crew was unware of the drum contents, they didn’t know the best way to contain the fire.

But are Li-ion batteries an EPA-regulated hazardous waste? Kerchner explained that before a material can be designated hazardous waste, it first must be a “solid waste”, which is defined as “discarded, abandoned, recycled, or otherwise inherently waste-like”. A solid waste is considered “hazardous waste” if it is specifically named by EPA, or a “characteristic waste for ignitability, reactivity, corrosivity, or toxicity.”

But when does a Li-ion cell, battery module or battery assembly become waste? When the batteries, for instance in an electric vehicle, are no longer up to the job, they may see a second life being refurbished for other applications. So are they considered waste when they are removed from the vehicle or tested at the recovery facility? Is the waste the actual cell, the module, or the battery assembly? The answers will depend on the cell condition and if it will be recycled or reused. If reused, whether it will it be used as a whole or in part with individual cells.

If a company ships used cells to a battery assembler for refurbished use, is it a hazardous waste shipment? If it isn’t, is UN38.3 testing required?

Kerchner didn’t explore all of the angles but he emphasized that Li-ion batteries should at least be managed as universal waste, and are subject to EPA regulations for disposal and US Department of Transportation rules for transport. For instance, the EPA regulations stipulate that a company disposing of batteries must notify EPA, contain leaking cells or batteries, label the batteries or containers of batteries as “universal waste batteries”, “waste batteries”, or “used batteries”, and employee training on battery handling and emergency procedures.

When a company is exporting Li-ion batteries as hazardous waste it must obtain an EPA ID number before arranging for export, establish a written contract with the receiving recycling or disposal facility, file annual reports with EPA, and package and ship the batteries in accordance with IMDG Code.

The 35th International Battery Seminar was held on March 26-29 in Fort Lauderdale, Florida. The conference is produced by Cambridge EnerTech, the parent company of Battery Power Online.