Lithium batteries can be found in an exceptionally wide range of devices – from smartphones to electric vehicles. While these batteries have made our lives incredibly convenient, they also pose significant challenges – especially when it comes to end-of-life management and reverse logistics.
The reverse logistics process – which involves the handling, transportation, and disposal of lithium batteries after their initial sale – plays a critical role in sustainable waste management and resource recovery.
If you are someone who is involved in the reverse logistics supply chain for lithium batteries, it is important for you to be aware of the hazmat regulations that are applicable to the transportation of damaged, defective, or recalled (DDR) lithium batteries. Failing to comply with these regulations can not only increase the risk of hazmat incidents significantly, but also result in legal consequences – including fines, penalties, and potential liability for damages.
Does the Hazmat Reverse Logistics Exception Apply to Lithium Batteries?
No. While the Pipeline and Hazardous Materials Safety Administration (PHMSA) does provide certain exceptions to hazardous materials shipped in limited quantities in the reverse logistics supply chain, these exceptions do not apply to lithium batteries.
Why Aren’t the Exceptions for Hazmat Reverse Logistics Applicable to Lithium Batteries?
49 CFR § 173.157 provides a special exception for reverse logistics shipments of certain hazardous materials in limited quantities. This exception – commonly referred to as the reverse logistics exception – provides regulatory relief to shippers who are involved in the hazmat reverse logistics supply chain. Thanks to this exception, shippers are not required to comply with all the packaging, training, and hazard communication regulations that are applicable to regular hazmat shipments.
The primary purpose of the reverse logistics exception is to reduce the regulatory burden for hazmat shippers in the reverse logistics supply chain. The PHMSA believes that the hazardous materials that are exempted under the reverse logistics exception pose a level of risk that can be managed with minimal regulatory requirements.
When it comes to shipping lithium batteries, the aforementioned exception is not applicable, because these batteries pose a greater risk than the hazardous materials that are exempted under Section 173.157.
In fact, damaged, defective, or recalled lithium batteries pose a much greater risk than normal batteries – particularly during transportation. These batteries are prone to thermal runaway – a chemical process where a battery’s temperature rapidly increases and leads to a self-sustaining reaction – potentially leading to a fire or explosion. During transportation, physical shocks, punctures, exposure to extreme temperatures, and a number of other factors can exacerbate these risks and increase the likelihood of hazmat incidents.
Moreover, when lithium batteries burn, they tend to release toxic gases like carbon monoxide and hydrogen fluoride, which are extremely harmful to health. If hazmat personnel are exposed to these gases in an enclosed transportation environment, the consequences can be life-threatening.
Simply put, the level of risks posed by damaged, defective, or recalled lithium batteries – even in small quantities – cannot be managed with minimal regulatory requirements. It is why regular lithium battery shipments as well as reverse logistics shipments are subject to the same kind of regulations.
How to Determine If a Lithium Battery Is Defective or Damaged?
If you are a shipper, it is your responsibility to determine whether the lithium batteries you intend to ship are damaged or defective and take the necessary safety precautions. Common signs of physical or mechanical damage to look for in lithium batteries include:
- If the battery appears swollen
- If the battery is leaking or venting
- If the battery case is discolored
- If the wires are loose or damaged
Apart from this, if a lithium battery shipment appears to be defective or damaged or if it is suspected to be defective or damaged, you should take all the necessary safety precautions – even if there are no signs of physical or mechanical damage.
Ship Lithium Batteries Safely: Choose Hazmat University’s Online Hazmat Training Courses
If you are involved in any capacity in the transportation of lithium batteries by air, ground, or vessel, you need to be properly trained and you should be aware of the hazmat regulations you need to comply with. At Hazmat University, we offer state-of-the-art online courses for hazmat personnel who are involved in the transportation of lithium batteries.
Our courses cover all the applicable federal and international regulations for transporting lithium battery shipments – from the identification and classification of lithium cells and batteries to packing, marking, labeling, placarding, and preparing shipping papers.
We offer specific courses for the transportation of lithium batteries by air, ground, and vessel. We also offer multimodal courses that cover the regulatory requirements for multiple modes of transportation. Designed by industry experts with decades of experience, our courses allow you to learn and get trained at a comfortable pace – no matter where you are.
Call us today at 844-376-4076 or contact us online to order your lithium batteries training courses.
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