The International Air Transport Association (IATA) is the industry’s global trade association and represents some 290 airlines comprising 82% of global air traffic. Its mission is to represent, lead and serve the air transport industry. Air cargo is essential to many facets of modern life. The pharmaceutical industry relies on air transport for its speed and efficiency in transporting high-value, time and temperature sensitive cargo.
The healthcare industry is increasingly using monitoring systems, which may be placed in individual packages, to track the temperature or other parameters of the product throughout its journey across the whole distribution chain. These track and trace devices, such as electronic temperature data loggers are used on or in passive packages. Different types of active transmitting devices with advanced monitoring and tracing real time functionalities are also available on the market. It is important to understand that temperature monitoring devices containing lithium cells or batteries (commonly lithium metal cells/batteries) are classified as dangerous goods in air transport. Lithium batteries represent a significant safety concern. Incorrectly manufactured and/or tested lithium batteries pose a fire risk in transport.
IATA Dangerous Goods Regulations (DGR)
All lithium batteries must be transported in accordance with the provisions set out in the IATA Dangerous Goods Regulations (DGR) for air transport, which are based on the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions). IATA also produces the Lithium Battery Shipping Guidelines (LBSG), a guidance document assisting the industry step by step throughout the shipping process. The LBSG also demonstrate how to safely and efficiently prepare lithium battery shipments in compliance with international air transport regulations. The LBSG provides all the relevant content from the DGR with additional classification flowcharts and detailed packing and documentation examples specifically for lithium batteries.
Supporting the safe transportation of lithium batteries by air
Lithium cells and batteries are classified as dangerous goods and can pose a safety risk if not prepared and shipped in compliance with the applicable provisions of the DGR when transported by air. This applies regardless of whether the lithium cells or batteries are shipped as cargo in their own right or whether the lithium cells or batteries are installed in a small device such as a data logger that is placed inside or attached to packages of cargo. In addition, to be permitted in transport all lithium cell and battery types must have passed the applicable tests set out in Subsection 38.3 of the UN Manual of Tests and Criteria.
Transporting lithium cells and batteries or lithium battery powered equipment is complex, but the following information and other guidance provided by IATA will assist stakeholders involved in supply chain to be fully compliant.
How to identify if lithium cells or batteries are dangerous goods and how to pack them?
The extent to which the lithium cells or batteries are regulated as dangerous goods depends on:
(a) the lithium metal content for lithium metal cells or batteries; or
(b) the Watt-hour (Wh) rating for lithium ion cells or batteries.
Packages containing lithium batteries installed in equipment such as a data logger must bear the lithium battery mark as shown in Figure 7.1.C of the IATA DGR, see Figure 1.
1. the lithium battery mark is not required on packages where the data loggers are powered by only button (coin) cells (regardless of the quantity of data loggers in a particular package or the number of packages in a consignment);
2. the lithium battery mark is not required on packages where there are no more than 4 cells or 2 batteries contained in equipment in each package and there are no more than two packages in the consignment.
Where the packages are of dimensions such that they cannot bear the full size lithium battery mark, the mark dimensions may be reduced to 105 mm wide × 74 mm high. The design specifications otherwise remain the same.
The lithium battery mark must bear the UN number and a telephone number of a person knowledgeable of the shipment, but is not intended to be for the purposes of obtaining immediate emergency response guidance, and is therefore not required to be monitored at all times while the package is in transit.
Training of employees involved in preparing packages with temperature monitoring devices is key to ensuring full compliance with the regulations. For packages bearing the lithium battery mark, employees must be provided with “adequate instructions”.
The following is offered as a starting point for an employer on what could be considered as being adequate instruction:
1. The employer must identify the different configurations of lithium batteries that they ship, i.e. lithium batteries and/or lithium batteries packed with equipment and/or lithium batteries contained in equipment; lithium metal batteries and/or lithium ion batteries.
2. The employer must document the procedures that apply to the configurations and battery types that they ship as determined in 1, above. IATA Battery Powered Data Logger Guidance Document – 2017 V1 APCS/Cargo Page 5 31/01/2017
3. The procedures should be written up as a clear work instructions or other form of information that is available to all employees responsible for the preparation of lithium battery shipments.
4. All employees that are involved in the process of preparing lithium battery shipments must be taken through the procedure to ensure that they understand and can demonstrate the correct application of documented procedures for the packing, labelling, marking and documentations requirements, as applicable to their job function.
5. A record must be maintained that identifies each applicable employee and the date(s) that this instruction was provided.
6. Employees should be given periodic refresher, or at least demonstrate that they remain “adequately” instructed on how to perform the task. This should be done at least every two years or whenever the procedure is revised, or regulations are changed, whichever is sooner.
7. Companies that are involved in reverse logistics, i.e. arranging for returns of lithium batteries, lithium batteries packed with equipment or lithium batteries contained in equipment must develop a clear instruction for consumers on the process to be followed for returning products. This instruction must include packaging materials and lithium battery marks, as necessary. The instruction must also include the transport method and mode of transport to be followed; this must include a clear statement on applicable prohibitions.
Data loggers and cargo tracking devices have the potential to interfere with aircraft navigation or communication systems since they are designed to remain active throughout their entire transport from the shipper to the consignee, including when on board an aircraft.
Because they cannot be turned off manually in the event of an emergency, the device manufacturers and aircraft operators must ensure certain design and operational considerations are addressed. Areas for consideration include:
RF radiated emissions limits
the device is designed with a minimum of two independent means to turn off completely turn off cellular or mobile functions, or a combination of both when airborne
the device must not be capable of generating a dangerous evolution of heat
the device must not be capable of emitting disturbing signals, such as buzzing alarms or strobe lights, during transport.
It is recommended that manufacturers of devices that are intended to be placed into, or attached to cargo, make contact with operators in advance so that the approval / authorization can be coordinated. This will avoid the need for multiple individual shippers to seek approval / authorization for the same device.
Effective 1 January 2020, manufacturers and subsequent distributors of cells or batteries manufactured after 30 June 2003 must make available the test summary as specified in the UN Manual of Tests and Criteria, Part III, sub-section 38.3, paragraph 38.3.5. The test summary must include the following information:
Finally, IATA is working with the industry for the industry. There will be continuous development of the standards to reinforce IATA’s objective to be the force for value creation and innovation, driving a safe, secure and sustainable air transport industry that connects and enriches our world.