Where Do I Find Lithium Batteries and How Do I Ship Them?

Lithium batteries continue to be a particular concern in the aviation world.  For many aircraft parts distributors, it is important to be able to recognize the presence of lithium batteries in an article or assembly in order to be able to ensure that the article or assembly is shipped properly.

Some known uses of lithium batteries on airplanes include:

  • Flight deck and avionics systems such as displays, global positioning systems, cockpit voice recorders, flight data recorders, underwater locator beacons, navigation computers, integrated avionics computers, satellite network and communication systems, communication management units, and remote-monitor electronic line-replaceable units;
  • Cabin safety, entertainment, and communications equipment, including emergency locator transmitters, life rafts, escape slides, seat belt air bags, cabin management systems, Ethernet switches, routers and media servers, wireless systems, internet and in-flight entertainment systems, satellite televisions, remotes, and handsets;
  • Systems in cargo areas including door controls, sensors, video surveillance equipment, and security systems.

Source: Special Conditions: AmSafe; Non-Rechargeable Lithium Battery Installations, 82 F.R. 14164, 14165 (March 17, 2017).

Once you have identified a lithium battery, you need to ascertain the correct proper shipping name for the battery.  There are currently six main proper shipping names that apply to lithium battery configuration:

  • Lithium Ion Batteries
  • Lithium Ion Batteries Contained in Equipment
  • Lithium Ion Batteries Packed with Equipment
  • Lithium Metal Batteries
  • Lithium Metal Batteries Contained in Equipment
  • Lithium Metal Batteries Packed with Equipment

Each of these proper shipping names leads to a different packing instruction or packing regulation, and different standards for how to identify, package and ship the articles.  Most aircraft batteries are lithium ion, but it is important to properly classify the battery before you ship it.

The rules concerning shipping lithium batteries as hazardous materials (US term) or dangerous goods (international term) have been changing frequently in recent years.  This is meant to ensure that they are shipped safely, based on the latest knowledge.  But these changes in the standards can make compliance difficult.  In order to ensure compliance, we recommend that you always do these things:

  • Before you even consider shipping a hazardous material, make sure you are trained and that your training is current (it’s the law!);
    • We offer a live, interactive, online course for hazmat certification;
  • Pick up the current version of the relevant regulations (e.g. US DOT regulations or the ICAO Technical Instructions) and read the relevant requirements;
  • Read through the packing instruction or packing regulation carefully (yes, even though you know it, read it again, right before using it);
  • Identify what subsection of the packing instruction or packing regulation applies to your shipment (there are usually tw0 [I/II] or three [IA, IB, II] different subsections that could apply in each IATA/ICAO packing instruction – you must choose the correct subsection based shipping configuration factors like mass, watt-hour rating, number of batteries, etc.);
  • Follow the instructions carefully and don’t get mixed-up (when using the IATA DGR Packing Instructions, you should be following the instructions in your proper subsection and also the general instructions at the beginning of the packing instruction that apply to all of the subsections).

On April 5-6, 2017 we will be conducting an online class on how to ship aircraft parts when the parts are characterized as hazardous materials or dangerous goods. The class includes units and exercises designed to help you identify hazardous materials in aviation, in addition to teaching you how to package, identify and ship them.

Those who successfully pass the course will be certified in accordance with US DOT regulations and IATA/ICAO standards.  The class is inexpensive and there are additional discounts for trade association members.  It is also a live, online class.  Since it is taught online, you can participate from the comfort of your own desk, with no need to travel.  Since it is also live, you can ask the instructor questions and get answers immediately.

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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