COMMODITY: Alkaline batteries, including Ni-MH Nickel Metal Hydride. These are mostly not regulated as dangerous goods except for basic packaging requirements to prevent short circuits and damage, and reporting is required in the rare case of an incident. Some additional requirements apply to sea and air transport, but the shipments are not generally impeded compared to non-hazardous goods.
MODE OF TRANSPORTATION: International Air
OVERVIEW
| PROPER SHIPPING NAME: | Batteries, dry; Batteries, nickel-metal hydride | LABEL: | No |
| IDENTIFICATION NUMBER: | None, or UN 3496 for Ni-MH | PLACARD: | N/A |
| HAZARD CLASS/DIVISION: | None, or 9 for Ni-MH | EMERG. INFO: | No |
| PACKING GROUP: | None | TRAINING: | No |
| DOCUMENT: | Air Waybill only | PACKAGING: | Special |
| MARKING: | No |
DANGEROUS GOODS TABLE
CLASSIFICATION
Alkaline batteries, including nickel-metal hydride (Ni-MH), are mostly not regulated.
Citation: 49 CFR 172.101 HazMat Table, entry for Batteries, dry, sealed, n.o.s.
SPECIAL PROVISIONS
These batteries are mostly exempted from the dangerous goods regulations, and the remaining requirements are contained in SP A199 for Ni-MH batteries or in SP A123 for all other alkaline batteries. The results are the same between SP A123 and A199 except the way they must be noted on the air waybill. The full text of the special provisions follow (certain parts of these may be replicated in other sections of this transport data sheet):
SPECIAL PROVISION A123 – SEALED ALKALINE BATTERIES OTHER THAN NI-MH
A123 This entry applies to Batteries, electric storage, not otherwise listed in Subsection 4.2–List of Dangerous Goods. Examples of such batteries are: alkali-manganese, zinc-carbon and nickel-cadmium batteries. Any electrical battery or battery powered device, equipment or vehicle having the potential of a dangerous evolution of heat must be prepared for transport so as to prevent:
(a) a short-circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals; or, in the case of equipment, by disconnection of the battery and protection of exposed terminals); and
(b) unintentional activation.
The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is issued.
SPECIAL PROVISION A199 – NI-MH ALKALINE BATTERIES
A199 The UN number UN 3496 is only applicable in sea transport. Nickel-metal hydride batteries or nickel-metal hydride battery-powered devices, equipment or vehicles having the potential of a dangerous evolution of heat are not subject to these Regulations provided they are prepared for transport so as to prevent:
(a) a short circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals; or, in the case of equipment, by disconnection of the battery and protection of exposed terminals); and
(b) unintentional activation.
The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill required by 8.2.6, when an Air Waybill is issued.
Citation: IATA 4.4, SP 123 and A199
PACKAGING
Any electrical battery or battery powered device, equipment or vehicle having the potential of a dangerous evolution of heat must be prepared for transport so as to prevent:
(a) a short-circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals; or, in the case of equipment, by disconnection of the battery and protection of exposed terminals); and
(b) unintentional activation.
Also follow the following USA requirements. Batteries and battery-powered device(s) containing batteries must be prepared and packaged for transport in a manner to prevent:
(1) A dangerous evolution of heat;
(2) Short circuits, including but not limited to the following methods:
(i) Packaging each battery or each battery-powered device when practicable, in fully enclosed inner packagings made of non-conductive material;
(ii) Separating or packaging batteries in a manner to prevent contact with other batteries, devices or conductive materials (e.g., metal) in the packagings; or
(iii) Ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means; and
(3) Damage to terminals. If not impact resistant, the outer packaging should not be used as the sole means of protecting the battery terminals from damage or short circuiting. Batteries must be securely cushioned and packed to prevent shifting which could loosen terminal caps or reorient the terminals to produce short circuits. Batteries contained in devices must be securely installed. Terminal protection methods include but are not limited to the following:
(i) Securely attaching covers of sufficient strength to protect the terminals;
(ii) Packaging the battery in a rigid plastic packaging; or
(iii) Constructing the battery with terminals that are recessed or otherwise protected so that the terminals will not be subjected to damage if the package is dropped.
ADDITIONAL AIR TRANSPORT PACKAGING – BATTERIES >9V
For a battery whose voltage exceeds 9 volts—
(1) When contained in a device, the device must be packaged in a manner that prevents unintentional activation or must have an independent means of preventing unintentional activation (e.g., packaging restricts access to activation switch, switch caps or locks, recessed switches, trigger locks, temperature sensitive circuit breakers, etc.).
Citation: 49 CFR 172.102 Special Provision 130
INCIDENT REPORTING
For transportation by aircraft, a telephone report in accordance with §171.15(a) is required if a fire, violent rupture, explosion or dangerous evolution of heat (i.e., an amount of heat sufficient to be dangerous to packaging or personal safety to include charring of packaging, melting of packaging, scorching of packaging, or other evidence) occurs as a direct result of a dry battery.
Additionally, for all modes of transportation, a written report submitted, retained, and updated in accordance with §171.16 is required if a fire, violent rupture, explosion or dangerous evolution of heat occurs as a direct result of a dry battery or battery-powered device.
Citation: 49 CFR 172.102 Special Provision 130
DOCUMENTATION REQUIREMENTS
There is no requirement for a dangerous goods declaration (shipping paper).
The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill required by 8.2.6, when an Air Waybill is issued.
CARTON MARKING
There are no mandatory carton marking requirements.
The following illustration shows a sticker available from LabelMaster. There is a scenario for US domestic air transport where this is one of a couple options. This is not recommended for international air shipments, but does not need to be removed if present.
TRAINING
None.