United Nations: Protocol summary of the UN Sub-Committee of Experts on the Transport of Dangerous Goods Sixty-fourth session, Geneva, 24 June - 3 July 2024

We had the overview of topics in our last newsletter. And now we added a summary of the protocol for each of the topics.

2.1  Hazard-Based System for Classification of Lithium Batteries (Document ST/SG/AC.10/C.3/2024/13) 

• State and Organization: Transmitted by the experts from Belgium and France and by the Advanced Rechargeable and Lithium Batteries Association (RECHARGE) on behalf of the informal working group.
• Introduction: There's a need for a more detailed hazard-based classification system for lithium batteries to improve safety and regulatory compliance. The current system does not sufficiently differentiate between various types of lithium batteries and their specific hazards.
• Proposal: Develop a new classification system with multiple hazard categories and corresponding UN numbers for lithium and sodium ion batteries. This system aims to better reflect the varying hazards posed by different battery types. It will also facilitate the development of more targeted safety measures and transport conditions. The proposal includes detailed testing protocols and classification criteria to ensure accurate hazard assessment.
• Protocol - summary: The UN Sub-Committee of Experts outlines several key conclusions and actions to be undertaken. It concludes that the current classification system is inadequate for addressing the specific hazards of different types of lithium batteries. Therefore, a new hazard-based classification system is essential. The protocol details the establishment of a working group to develop these new categories and corresponding UN numbers, with a focus on improving the precision of hazard assessments and safety measures.
• Protocol - Actions: The working group will develop detailed testing protocols and classification criteria for lithium and sodium ion batteries. The group is tasked with finalizing the new classification system by the end of 2025, with an interim report to be presented in mid-2025.
• Protocol - Time Frames: The new classification system is expected to be implemented in stages, with initial testing and feedback phases completed by 2025, followed by full integration into the UN Model Regulations by 2026. These actions are intended to ensure that the new classification system not only addresses the identified gaps but also aligns with global safety and regulatory standards for the transport of dangerous goods.

2.2 Amendment to the T.5 Short Circuit Test (Document ST/SG/AC.10/C.3/2024/15)

• State and Organization: Submitted by the Advanced Rechargeable & Lithium Batteries Association (RECHARGE).
• Introduction: New battery designs, such as those for wireless charging, make it impossible to access terminals without dismantling the battery, complicating the short circuit test. This can hinder the verification of safety measures in place.
• Proposal: Allow a verification process for these batteries, where dismantling is performed following manufacturer guidelines to check the effectiveness of short circuit protection after tests. This change will ensure that even new battery designs can be adequately tested for safety. It will also align the testing procedures with the practical realities of modern battery designs. This proposal will help maintain high safety standards without compromising the integrity of new battery designs.
• Protocol - Summary: The UN Sub-Committee of Experts concludes that the existing T.5 Short Circuit Test is not suitable for all new battery designs, particularly those that do not allow direct access to terminals. The proposed amendment will allow dismantling of the batteries per manufacturer guidelines to verify short circuit protection.
• Protocol - Actions: A technical committee is to review and finalize the updated testing procedures by mid-2025. The revised procedures will be integrated into the existing testing framework by the end of 2025.
• Protocol - Time Frames: The updated T.5 Short Circuit Test procedures are to be fully implemented by the beginning of 2026, with a review of their effectiveness scheduled for 2027.

2.3  Clarification of Battery Mark Requirements (Document ST/SG/AC.10/C.3/2024/28)

• State and Organization: Transmitted by the experts from Canada and China.
• Introduction: The current marking requirements for lithium batteries in the Model Regulations are ambiguous, particularly in special provision 188. This ambiguity leads to inconsistencies in how lithium batteries are marked for transport, potentially compromising safety.
• Proposal: Amend special provision 188 to ensure it references all requirements under 5.2.1.9, not just the illustration, thus closing a regulatory gap and ensuring consistency. This change will make the regulations clearer and easier to follow for manufacturers and transporters. It will also enhance the overall safety of lithium battery transport. Ensuring clear and consistent marking will help in the proper handling and identification of lithium batteries during transport.
• Protocol - summary: The UN Sub-Committee of Experts identifies ambiguities in the current marking requirements, which can lead to inconsistent and potentially unsafe practices. The conclusion is that clearer, more consistent marking regulations are needed.
• Protocol - Actions: Amend special provision 188 to include comprehensive references to all relevant requirements, ensuring uniformity in marking practices. Conduct training sessions for manufacturers and transporters on the new marking requirements by the end of 2024.
• Protocol - Time Frames: The amendments are to be incorporated into the Model Regulations by early 2025, with mandatory compliance for all stakeholders by mid-2025.

2.3  Alignment Between Requirements of 2.0.5.6 and Special Provision 301 (Document ST/SG/AC.10/C.3/2024/35)

• State and Organization: Submitted by the expert from China.
• Introduction: Inconsistencies exist between paragraph 2.0.5.6 and special provision 301 regarding the enclosure of dangerous goods. These inconsistencies can cause confusion and potentially unsafe transport conditions.
• Proposal: Amend both sections to ensure only dangerous goods that could react dangerously need separate enclosure, providing a more practical and safe regulatory approach. This amendment will make the regulations more coherent and easier to follow. It will also enhance the safety of transporting multiple dangerous goods in a single package. The proposed changes will streamline the regulatory requirements, reducing complexity and potential errors.
• Protocol - summary: The UN Sub-Committee of Experts concludes that the inconsistencies between paragraph 2.0.5.6 and special provision 301 need to be resolved to prevent potential safety issues during transport. The alignment of these provisions is crucial for ensuring safe and efficient transport practices.
• Protocol - Actions: Amendments will be made to both paragraph 2.0.5.6 and special provision 301 to clarify the requirements for enclosing dangerous goods. A cross-functional working group will be established to ensure that these changes are effectively communicated and implemented.
• Protocol - Time Frames: The alignment of these provisions is to be completed by the end of 2024, with full compliance required by mid-2025.

2.5 Size of Flat Surfaces in Crush Test Procedure (Document ST/SG/AC.10/C.3/2024/39)

• State and Organization: Transmitted by the expert from China.
• Introduction: The crush test procedure for large batteries is currently insufficient due to undefined surface dimensions. This lack of specificity can lead to inconsistent test results and potential safety hazards.
• Justification and Proposal: Specify that the surfaces used in crush tests must be larger than the battery's largest side to ensure accurate testing and safety. This change will standardize the testing process and improve the reliability of the results. Ensuring proper testing conditions is crucial for validating the safety of large batteries during transport. Standardizing surface dimensions in testing will prevent variances that could affect the test outcomes.
• Protocol - Summary: The protocol concludes that the lack of specific surface size requirements in the crush test procedure can lead to unsafe outcomes. The proposed amendment will standardize the surface dimensions used in testing to ensure consistent and reliable results.
• Protocol - Actions: Update the Manual of Tests and Criteria to include specific dimensions for surfaces used in crush tests. Conduct validation studies on the new procedures by early 2025 to ensure their effectiveness.
• Protocol - Time Frames: The revised crush test procedures are to be implemented by mid-2025, with industry-wide adoption expected by early 2026.

2.6 New Special Provision for All-Solid-State Lithium Ion Cells and Batteries (Document ST/SG/AC.10/C.3/2024/42)

• State and Organization: Transmitted by the expert from Japan.
• Introduction: All-solid-state lithium ion batteries, which do not cause thermal runaway, are not adequately addressed in current regulations. These batteries offer significant safety advantages that should be recognized in transport regulations.
• Proposal: Introduce a special provision for these batteries to simplify transport procedures and enhance safety, linked to sustainable development goals. This will involve setting specific criteria that these batteries must meet to qualify for the special provision. The new regulations aim to encourage the use of safer battery technologies while maintaining strict safety standards. Recognizing the unique safety features of all-solid-state batteries will promote their adoption and improve overall transport safety.
• Protocol - Summary: The protocol concludes that the unique safety advantages of all-solid-state lithium-ion batteries warrant the creation of a new special provision. This provision will simplify the transport procedures for these batteries while ensuring that safety standards are met.
• Protocol - Actions: Draft and implement a new special provision specific to all-solid-state lithium-ion batteries. Develop and disseminate guidelines for compliance with the new provision to manufacturers and transporters by the end of 2024.
• Protocol - Time Frames: The special provision is expected to be integrated into the Model Regulations by mid-2025, with full compliance required by early 2026.

2.7 Additional Mitigation Measures for Lithium Battery Transport (Document ST/SG/AC.10/C.3/2024/45)

• State and Organization: Transmitted by the International Civil Aviation Organization (ICAO).
• Introduction: Following a safety risk assessment, ICAO recommended new restrictions on lithium battery transport, including state of charge limits. These measures aim to reduce the risk of incidents during air transport.
• Proposal: Include requirements for competent authority approval of testing laboratories and detailed quality assessments for manufacturers, including third-party verification. This will ensure that all testing is conducted to the highest standards, reducing the risk of transport incidents. The proposed measures will also promote better compliance with safety regulations.
• Protocol - Summary: The protocol concludes that additional restrictions and oversight are necessary to ensure the safe transport of lithium batteries by air. The recommendations include implementing state of charge limits and requiring competent authority approval for testing laboratories.
• Protocol - Actions: Introduce state of charge limits for lithium batteries during air transport. Implement a mandatory approval process for testing laboratories and establish third-party verification requirements by the end of 2024.
• Protocol - Time Frames: These measures are to be fully implemented by early 2025, with regular audits and reviews scheduled to ensure ongoing compliance.

2.8 Used Medical Devices Containing Lithium Batteries (Document ST/SG/AC.10/C.3/2024/51)

• State and Organization: Transmitted by the Council on the Safe Transportation of Hazardous Articles (COSTHA).
• Introduction: The current exemption for used medical devices does not include provisions for lithium batteries, complicating transport for disinfection and repair. This omission can lead to misclassification and safety risks during transport.
• Proposal: Amend 2.6.3.2.3.9 to include lithium batteries, allowing these devices to be classified under UN 3481 or UN 3091, facilitating safer and more efficient transport. This will provide clear guidelines for the safe transport of used medical devices containing lithium batteries. The proposal aims to enhance safety and streamline regulatory compliance for transporting these devices.
• Protocol - Summary: The protocol concludes that the existing regulations inadequately address the transport of used medical devices containing lithium batteries, potentially leading to safety risks. The amendment to section 2.6.3.2.3.9 will explicitly include provisions for these batteries, ensuring proper classification and safer transport.
• Protocol - Actions: Amend the existing exemption in section 2.6.3.2.3.9 to cover lithium batteries in used medical devices. Develop guidelines for manufacturers and transporters to comply with the new classification by the end of 2024.
• Protocol - Time Frames: The amendments are to be finalized and adopted by mid-2025, with mandatory compliance expected by the beginning of 2026.

2.9 Exception for Equipment Containing Both Lithium Batteries and Lithium Button Cells (Document ST/SG/AC.10/C.3/2024/53)

• State and Organization: Transmitted by the International Air Transport Association (IATA).
• Introduction: Current regulations do not differentiate between lithium batteries and button cells in equipment, causing complications. This lack of differentiation can lead to unnecessary regulatory burdens and potential safety issues.
• Proposal: Amend special provision 188 and 5.2.1.9.2 to exclude button cells from counting towards package limits when transported with other lithium batteries. This change will simplify the transport regulations and reduce confusion. The amendment will help ensure that regulatory requirements are practical and do not impose unnecessary burdens on transporters.
• Protocol - Summary: The protocol concludes that the differentiation between lithium batteries and button cells is necessary to prevent undue regulatory burdens and ensure safety. The amendment will simplify the process by excluding button cells from counting towards package limits, thus reducing confusion.
• Protocol - Actions: Amend special provision 188 and 5.2.1.9.2 to clarify the exclusion of button cells from package limits. Communicate these changes to industry stakeholders and provide training on the new requirements by the end of 2024.
• Protocol - Time Frames: The revised provisions are to be implemented by mid-2025, with full compliance expected by the end of 2025.

2.10 Reuse, Repair, and Repurposing of Lithium-Ion Batteries (Document ST/SG/AC.10/C.3/2024/55)

• State and Organization: Submitted by PRBA – The Rechargeable Battery Association and Advanced Rechargeable and Lithium Batteries Association (RECHARGE).
• Introduction: Governments and NGOs promote a circular economy, encouraging the reuse and repurposing of lithium-ion batteries. However, this raises safety and regulatory concerns under UN 38.3 testing requirements. Ensuring safety during the repurposing process is crucial to prevent transport incidents.
• Proposal: Add a new provision in section 38.3.2.1 to address design changes from repurposing, remanufacturing, or repairing batteries, emphasizing the need for retesting if these changes might affect safety. This will involve setting specific criteria for what constitutes a significant design change. The goal is to maintain high safety standards while supporting sustainability initiatives. This amendment will help ensure that repurposed batteries are as safe as new ones.
• Protocol - Summary: The protocol concludes that as the industry moves towards greater sustainability, the repurposing and remanufacturing of lithium-ion batteries must be regulated to maintain safety standards. The new provision in section 38.3.2.1 will require batteries that undergo significant design changes during repurposing to be retested to ensure safety.
• Protocol - Actions: Introduce a new provision in section 38.3.2.1 to cover the retesting of repurposed, remanufactured, or repaired batteries. Establish guidelines for identifying significant design changes that necessitate retesting, to be finalized by the end of 2024.
• Protocol - Time Frames: The new provisions are to be adopted by mid-2025, with the retesting requirements enforced by the end of 2025.

2.11 UN 38.3 Lithium Battery Test Sequence – Clarification (Document ST/SG/AC.10/C.3/2024/56)

• State and Organization: Transmitted by PRBA – The Rechargeable Battery Association.
• Introduction: The sequence of tests T.1 to T.5 in section 38.3.4 is often misinterpreted, causing operational inefficiencies. Clarifying the sequence will help testing laboratories and manufacturers ensure compliance without unnecessary delays.
• Proposal: Amend the text to clarify that tests can be conducted out of sequence as long as cumulative stress is applied, with T.5 being the last test due to its destructive nature. This will allow more flexibility in the testing process, making it more efficient while maintaining safety standards. Adjusting the sequence will prevent delays caused by rigid testing procedures.
• Protocol - Summary: The protocol concludes that the current sequence of tests T.1 to T.5 has been misinterpreted, leading to inefficiencies. The amendment will clarify that the tests can be conducted out of sequence, except for the destructive T.5 test, which must remain last. This will provide more flexibility in the testing process while ensuring that cumulative stress conditions are maintained.
• Protocol - Actions: Amend section 38.3.4 to clarify the flexibility in the sequence of tests while maintaining safety standards. Update the testing guidelines and provide training to laboratories by the end of 2024 to ensure understanding and compliance.
• Protocol - Time Frames: The clarified testing sequence is to be implemented by mid-2025, with a review of its impact on testing efficiency and safety scheduled for 2026.

2.12 UN 38.3 Lithium Battery Test Sequence – Clarification (Document ST/SG/AC.10/C.3/2024/56)

• State and Organization: Transmitted by PRBA – The Rechargeable Battery Association.
• Introduction: The sequence of tests T.1 to T.5 in section 38.3.4 is often misinterpreted, causing operational inefficiencies. Clarifying the sequence will help testing laboratories and manufacturers ensure compliance without unnecessary delays.
• Proposal: Amend the text to clarify that tests can be conducted out of sequence as long as cumulative stress is applied, with T.5 being the last test due to its destructive nature. This will allow more flexibility in the testing process, making it more efficient while maintaining safety standards. Adjusting the sequence will prevent delays caused by rigid testing procedures.
• Protocol - Summary: The protocol concludes that clarifying the test sequence in UN 38.3 is necessary to reduce operational inefficiencies and prevent delays. It specifically emphasizes that while flexibility in the sequence is allowed, the destructive T.5 test must always be conducted last to ensure safety.
• Protocol - Actions: Amend section 38.3.4 to allow flexibility in the sequence of tests while ensuring that cumulative stress is applied appropriately. Distribute updated guidelines to testing laboratories and manufacturers by the end of 2024.
• Protocol - Time Frames: The amendments are to be implemented by mid-2025, with compliance audits scheduled for early 2026 to ensure the new procedures are being followed correctly.