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The United States Pipeline and Hazardous Materials Safety Administration (”PHMSA”) addressed in an October 24th letter a question addressing the application of the Hazardous Materials Regulations (“HMR”) to lithium metal batteries contained in equipment.
PHMSA was responding to a June 19th query from Duke Energy of Raleigh, North Carolina.
Duke Energy states that it receives smart grid electric meters. Each of the meters contains a single lithium battery with a content of less than 2 grams of lithium per battery. Further, each smart grid electric meter contains a single lithium battery which will be classified as “UN3091, Lithium metal batteries contained in equipment, 9.”
The consignment is stated to include individual non-specification packages sent from the manufacturer containing 4 smart grid electric meters per box. Thirty of these non-specification packages are shrink-wrapped together to a pallet. This constitutes a total of 120 smart grid electric meters per pallet. Such shipments of the electric meters will be transported by highway.
Duke Energy asks the following questions:
- Will each package be required to be marked with the lithium battery mark?
PHMSA responds yes, stating:
Based on the information you provided, each package must display the lithium battery mark as required in§ 173.185(c)(3) since there are more than two packages in the consignment.
- The company also asks about the marking requirements if the manufacturer decides to ship all 120- smart grid electric meters in one non-specification rigid outer package (rather than four smart grid electric meters per box).
PHMSA responds:
. . . the outer package containing the 120 electric meters must display the lithium battery mark (see § 173. 185(c)(3)) as the package contains more than two lithium batteries contained in equipment.
A copy of the letter can be downloaded here.
