This summer, specialists from across the industry came together for our webinar,Managing Test Summary Requirements through Knowledge & Innovation , where we covered information on lithium battery test summary management and the new requirements under UN 38.3. In addition to sharing information, panelists answered the most difficult questions for participants and discussed how companies and industry partners around the world are addressing the challenges at hand and finding solutions through innovation. Here are some questions asked during the live event, which may also be applicable to your organization:
It was intended as a way to require airlines and cargo shippers to job seekers database request UN Safety Data Sheets (SDSs) and UN 38.3 test reports. To address this issue, some lithium battery and device manufacturers have made this information available, although this is not a widespread practice. The UN Model Regulations now require lithium battery manufacturers and distributors to provide lithium battery test summaries (TS) using a standardized set of elements. Listen to our webinar recording to hear more about how this requirement came into effect.
Is the TS a required shipping document? It is not intended to be a shipping document, but some freight forwarders request it. While it is not required, they may hold your shipment until you produce a TS; it is best practice to provide it upon request to avoid shipping delays. It is important to note that suppliers are required to have them for international shipments, both air and sea, based on ICAO TI (technical instructions) and the IMDG Code.
How does this impact organizations that do not manufacture or sell lithium batteries or products containing lithium batteries? Whether your company is shipping lithium batteries or products containing lithium batteries, you will be subject to the test summary requirement. Your freight forwarder may hold that shipment until you are able to produce a TS. Unfortunately, you are responsible for contacting the original equipment or battery manufacturer to obtain that test summary. Here is an example of how your organization can leverage CHMETREC’s CRITERIA service to help obtain the associated test summary.
How does the requirement affect shipping batteries for recycling? A lithium cell or battery, including a lithium cell or battery contained in equipment, that is transported in a motor vehicle to an approved storage facility or disposal site, or for recycling purposes, is exempt from the testing and recordkeeping requirements. See 173.185 paragraph (a) and the United Nations performance packaging requirements in paragraphs (b)(3)(ii), (b)(3)(iii), and (b)(6) of this section, when packed in a strong outer packaging that meets the applicable requirements of subpart B of this part. A lithium cell or battery that meets the size, packaging, and hazard communication conditions in paragraphs (c)(1)-(3) of this section is exempt from subparts C through H of part 172 of this subchapter.
How do you see the need evolving? The UN Subcommittee on Dangerous Goods has approved an exemption from the test summary for button cells installed in equipment and the removal of the signature requirement. These changes will take effect in January 2023. Future work on the test summary by the UN Subcommittee on Dangerous Goods includes changes to the applicable compliance date (i.e. batteries manufactured after 2003 are subject to a test summary), clarification of what is meant by “providing” the test summary should not include, and a new statement clarifying that OEMs are responsible for their lithium batteries if they are “refurbished.”