Does your company ship lithium batteries? How about lithium battery-powered devices like laptops or cell phones? If yes, you probably know the complexities that come with making shipments in compliance with both US DOT Hazardous Materials Regulations as well as international dangerous goods regulations. Well, you should also know that the regulations have changed recently, putting additional requirements on ALL companies that ship lithium batteries.
In March of this year, PHMSA adopted the Lithium Battery Test Summary requirement, which mandates manufacturers and subsequent distributors of lithium batteries and lithium battery-powered devices make available a specific document regarding each of their batteries. Lithium cells and batteries must pass a series of tests, described in the UN Manual of Tests and Criteria Part 3, Subsection 38.3, that are designed to demonstrate that the cells or batteries are safe for transport. The Lithium Battery Test Summary document must include detailed information about each cell or battery, place and date of testing, the tests conducted, and a signed certification that the cells or batteries have successfully passed the UN 38.3 test protocol (for more information on the content of this document, see PHMSA’s guidance here).
Whereas maintaining UN 38.3 test documentation used to apply solely to manufacturers, the regulators have expanded its scope to include any company that offers lithium batteries for shipment, including lithium battery-powered consumer electronic devices, electric vehicles, medical equipment, eBikes, and battery backup units. Already in effect in other countries, this requirement will become effective January 2022 in the USA.
This new documentation requirement puts a significant strain on battery shippers, especially those with hundreds or even thousands of different products that contain lithium batteries. Because the requirements are to make the Test Summary document available to regulators and stakeholders in the supply chain, these documents can either be created by the product distributor or you can use the Test Summary document produced by the original battery manufacturer. Though the latter option appears to be the more efficient route, many of these documents are exceedingly difficult to find. Gaining access to them often requires long online searches, phone calls to manufacturer’s customer assistance lines, or identifying direct contacts within the battery manufacturer’s company.
Given this reality, companies are approaching compliance to the Test Summary requirement in varying ways. For those with just a handful of lithium battery-powered products, seeking out and maintaining Test Summary documents is a minor burden. In other cases, companies have hired and trained a team of technicians to hunt down a Test Summary document for each of their hundreds or thousands of battery-powered products. Getting a Test Summary for each product is an uphill climb and comes at great cost in terms of time and labor.
For companies struggling to manage this documentation requirement in-house, we recommend exploring how ChemTrec can help. ChemTrec, a leader in emergency response services for dangerous goods shippers, has developed a Lithium Battery Test Summary document management system, CRITERION. Users of this system can upload and manage their company’s Test Summary documents in a secure, central location. Further, ChemTrec’s team of specialists are capable of sourcing test summary documents for your products that you are unable to locate and, should regulators, carriers, or freight forwarders request a Test Summary from your company, you can point them to ChemTrec who will handle the interaction on your behalf. Taken together, partnering with ChemTrec will significantly minimize the burdens of seeking out Test Summary documents as well as handling incoming requests for them.
If you are interested in hearing further details about how ChemTrec’s service will benefit your organization, don’t hesitate to reach out to me directly at MPagel@hazmatsafety.com
