Update on Changes in IMDG Code and ADR/RID Dangerous Goods Regulations Marco Ottaviani Dangerous Goods Safety Adviser Expert in Regulatory, Environmental, Safety and Transport Issues Vicenza Area, Italy marco.ottaviani1@gmail.com

Changes Common to All Transport Modes 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 ADR 2015

ADR 2013 vs 2015 Marco Ottaviani Dangerous Goods Safety Adviser Blue = amended Red = new

Use of Large Packaging for Lithium batteries 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 Is designed for mechanical handling Exceeds 400 kg net mass or 450 litres capacity but has a volume of not more than 3 m3

Special Provision 636b (as amended) 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: 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: Comply with packing instruction P909 (except short-circuit protection); A quality assurance system to ensure that the total amount of lithium cells or batteries per transport unit does not exceed 333 kg; Packages are marked “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING” as appropriate.”

Damaged or Defective Lithium Batteries 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

IMDG Code 2015 Large Packaging for lithium batteries LP 904 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!

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 …..

Special Provision 376 – Damaged or Defective Lithium Batteries Marco Ottaviani Dangerous Goods Safety Adviser IMDG Code 2015 Special Provision 376 – Damaged or Defective Lithium Batteries

Damaged or Defective Lithium ion Batteries? Marco Ottaviani Dangerous Goods Safety Adviser Damaged or Defective Lithium ion Batteries? 10