Feature
Lithium Battery Regulations
Nearly Short-Circuit
Healthcare Shipment
Monitoring
A company’s letter to the Department of Transportation is just one response to
the new restriction.
By Kevin O’Donnell, Director and Chief Technical Advisor,
Tegrant Corp., ThermoSafe Brands
The U.S.
Department
of Transportation Pipeline
and Hazardous
Materials Safety
Administration
(
DOT-PHM-SA) last year
amended the
H a z a r d o u s Kevin O’Donnell
Materials Regulations (HMR) expressly to tighten
the safety standards for lithium battery transportation. These amendments, they state, “will enhance
transportation safety by reducing fire
hazards associated with lithium batteries and harmonize U.S. and international standards.”
The final ruling, as it appears in the
DOT Dangerous Goods Regulations
(49 CFR Parts, 171, 172, 173, and 175,
Hazardous Materials; Transportation of
Lithium Batteries), became effective January 1, 2008. But like many Dangerous Goods Regulations, it is not without
controversy, ambiguity, and interpretation, which has led at least one passenger
airline to broadcast that they are no longer accepting cargo shipments containing devices powered by lithium batteries.
Such a knee-jerk
reaction sent a
leading temperature-monitoring
company scrambling to request
interpretation of
the Final Rule
from DOT,
while proving
that the batter-
Henry Ames
ies within their
devices are com-
pliant and/or meet the “special provisions” requirements for exceptions.
CRISIS AVERTED, FOR NOW
Direct negotiations with DOT on
behalf of the healthcare industry, IATA
Time and Temperature Task Force,
and the data-logging industry at large,
were led by Henry Ames, director of
strategic marketing for Sensitech Inc.
Sensitech, which has a vested interest
in the outcome, submitted a formal
request for interpretation of HMR 49
CFR Parts 171–180 to DOT. In a
prompt written response from PHMSA director Edward Mazzullo, DOT
said, “These cargo-monitoring devices
are subject to applicable provisions of
the HMR.” Based on the extensive
documentation Sensitech provided to
DOT relevant to its devices, however,
he added “that these devices qualify
for the exceptions provided for small
lithium batteries under SP 188” (49
CFR 172.102).
Will other device manufacturers have to provide similar letters
to DOT, to document the lithium
content and configurations of their
devices with the agency, and demonstrate conformity with the exception
requirements? Perhaps. The HMR
advises that “beginning October 1,
2009, the cells or battery must be of a
type proven to meet the requirements
of each test in the UN Manual of Tests
and Criteria 171.7.”
BUTTON-SIZED BATTERY
Lithium batteries are considered
a hazardous material for purposes of
transportation regulation because they
can overheat and ignite under certain
conditions and, once ignited, can be
difficult to extinguish. They come in a
near endless variety of shapes, sizes, and
densities and are defined by two types:
primary (nonrechargeable), which generally contain lithium metal, and secondary (rechargeable), containing an
ionic form of lithium. In comparison
with standard alkaline batteries, most
lithium-ion (rechargeable) batteries
