Question of the day: Your Question: Our supplier claims that he doesn´t need the UN 38.3 test for his products because this requirement is published the UN „Recommendations“ and is therefore only a recommendation. Is that correct?
Question of the day: Your Question: Our supplier claims that he doesn´t need the UN 38.3 test for his products because this requirement is published the UN „Recommendations“ and is therefore only a recommendation. Is that correct? I´m of a different opinion but I couldn´t find the source in the IATA DGR.
Question of the day:
Your Question:
Our supplier claims that he doesn´t need the UN 38.3 test for his products because this requirement is published the UN „Recommendations“ and is therefore only a recommendation. Is that correct?
I´m of a different opinion but I couldn´t find the source in the IATA DGR.
Our Answer:
The requirement for the UN Test Series 38.3 is published in the UN Recommendations on the transport of dangerous goods just as the manufacture according to quality management program. And your supplier is right, this document form the United Nations does not have legal character.
That´s why it was included in the ICAO Technical Instructions which are 1:1 represented in the IATA Dangerous Goods Regulations for air transport. In the ADR for road transport and in the IMDG Code for sea transport.
It was implemented into German law through the GGVSEB (regulation of the internal and transborder transport of dangerous goods on the road and with railroad).
A GGVLuft (regulation of the internal and transborder transport of dangerous goods in air transport) is in preparation. Until then the statement from the German Civil Aviation Authority (Luftfahrtbundesamt) that all requirements of the ICAO Technical Instructions need to be fulfilled is valid.
And for this reason each lithium cell and each lithium battery needs to have a declaration of confirmity that the UN Test Series 38.3 was successfully passed and also a confirmation that it was manufactured according to the Quality Management Program.
Without a confirmation of manufacture according to the Quality Management Program no transport is possible.
Without the declaration of confirmity that the UN Test Series 38.3 was successfully passed only the shipping of pre-production runs (max. production 100 pieces) and prototypes is allowed. Serial Products with a manufacture amount of more than 100 pieces without the UN 38.3 Test may not be placed on the marked at all.
In the IATA DGR the obligation hereto is listed under 3.9.2.6.1 (a). And in 3.9.2.6.1 (b) to (e) the other requirements are listed.
So you´re right. But it explains where the dangerous half-knowledge of your supplier comes from.
