Transcript ADR 2015 - Recharge Batteries

Marco Ottaviani
Dangerous Goods Safety Adviser
Expert in Regulatory,
Environmental, Safety and
Transport Issues
Vicenza Area, Italy
[email protected]
Marco Ottaviani
Dangerous Goods
Safety Adviser
Changes Common to All
Transport Modes
• Batteries are articles
• No packing group assigned
• Specific packaging performance level (e.g., PG II)
is identified in applicable packing instruction
• Applies to UN, IMDG Code, IATA, ICAO
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ADR 2015
Marco Ottaviani
Dangerous Goods
Safety Adviser
ADR 2013 vs 2015
Blue = amended
Red = new
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Marco Ottaviani
Dangerous Goods
Safety Adviser
ADR 2015
Use of Large Packaging for Lithium batteries
LP 903 (new batteries)
LP 904 (D&D batteries)
(Lack of LP for batteries for recycling or disposal)
"Large packaging" means a packaging consisting of an outer
packaging which contains articles or inner packagings and which
a) Is designed for mechanical handling
b) Exceeds 400 kg net mass or 450 litres capacity but has a volume
of not more than 3 m3
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Marco Ottaviani
Dangerous Goods
Safety Adviser
ADR 2015
Special Provision 636b (as amended)
I. Up to the intermediate processing facility, lithium cells and
batteries collected and transported for disposal or recycling:
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with a gross mass of not more than 500 g each
small excepted (SP 188)
whether or not contained in equipment
together with or without other non-lithium cells or batteries,
Are not subject to the other provisions of ADR including
 Special Provision 376 (D&D batteries) and
 paragraph 2.2.9.1.7 (general requirements of lithium batteries)
If they meet the following conditions:
1. Comply with packing instruction P909 (except short-circuit protection);
2. A quality assurance system to ensure that the total amount of lithium cells
or batteries per transport unit does not exceed 333 kg;
3. Packages are marked “LITHIUM BATTERIES FOR DISPOSAL” or
“LITHIUM BATTERIES FOR RECYCLING” as appropriate.”
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Marco Ottaviani
Dangerous Goods
Safety Adviser
ADR 2015
Damaged or Defective Lithium Batteries
• ADR 2013
• Special Provision 661 - Packaging conditions and authorization from
National Competent Authority
• Multilateral Agreement 259 (in countries which signed it) - Voluntary
application in advance of SP 376 + PI 908 or LP 904
• ADR 2015
• Special Provision 376 + PI 908 or LP 904
• Authorization of Competent Authority required for batteries in high
risk conditions only
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Marco Ottaviani
Dangerous Goods
Safety Adviser
IMDG Code 2015
• Large Packaging for lithium batteries
• LP 904
• New Special Provision and Packing Instruction for
lithium batteries “transported for disposal or recycling”
• SP 377 and P909: Always shipped as Class 9
dangerous goods!
• May also use P903 or SP 188
• New Special Provision and Packing Instructions for
damaged or defective lithium batteries
• SP 376 and P908 or LP 904: Always shipped as
Class 9 dangerous goods!
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Marco Ottaviani
Dangerous Goods
Safety Adviser
IMDG Code 2015
• New Special Provision 377 for lithium batteries
“transported for disposal or recycling”
Lithium ion and lithium metal cells and
batteries and equipment containing such
cells and batteries transported for disposal
or recycling, either packed together with or
packed without non-lithium batteries, may
be packaged in accordance with packing
instruction P909 …..
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Marco Ottaviani
Dangerous Goods
Safety Adviser
IMDG Code 2015
Special Provision 376 – Damaged or Defective Lithium Batteries
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Marco Ottaviani
Dangerous Goods
Safety Adviser
Damaged or Defective
Lithium ion Batteries?
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