The Lithium Battery Shipment That Almost Slipped Through
A freight forwarder presents a consignment of 40 cartons of UN3480 lithium ion batteries, packed in accordance with Section IA of Packing Instruction 965 (the batteries are shipped at a state of charge not exceeding 30% and are not in equipment). Each carton contains 12 batteries, each battery rated at 160 Wh. The shipper has completed a Shipper's Declaration for Dangerous Goods listing the proper shipping name as 'Lithium ion batteries', class 9, UN3480, packing group II, and has marked each carton with the lithium battery mark. The forwarder asks you to accept the shipment for a passenger aircraft. The total net quantity per package is 1.92 kg of batteries, and the shipper insists the documentation is correct because 'the batteries are under 100 Wh each'.
1. Evaluate whether the shipper's declaration and packing are correct for this shipment, identifying every error you can find.
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The shipper has made several errors. First, UN3480 lithium ion batteries shipped under Section IA of PI 965 are forbidden on passenger aircraft - they may only be carried on cargo aircraft. The forwarder's request to move them on a passenger aircraft must be refused outright.
Second, the shipper's claim that 'the batteries are under 100 Wh each' is contradicted by the facts: each battery is 160 Wh, which exceeds the 100 Wh threshold. Batteries above 100 Wh require Section IA packing and are subject to the full dangerous goods regime. The shipper appears to be confusing the 100 Wh limit that applies to the small battery exception (Section II) with the actual rated capacity.
Third, the packing group is wrong. Lithium ion batteries under UN3480 are not assigned a packing group - the entry in the Dangerous Goods List shows no PG. Listing 'II' is an error that must be corrected.
Fourth, the net quantity per package must be checked against the Section IA limit; 1.92 kg is within the limit, so the package quantity itself is acceptable, but the documentation errors still make the declaration invalid.
2. What markings and labelling must appear on each carton, and does the lithium battery mark alone satisfy the requirement?
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No - the lithium battery mark alone is insufficient for Section IA shipments. Each package must bear:
- The Class 9 hazard label (the lithium battery hazard label is used for Section II, but Section IA packages require the full Class 9 label).
- The proper shipping name and UN number marked on the package: 'UN3480, Lithium ion batteries'.
- The name and address of the shipper and consignee.
- The Cargo Aircraft Only label (since the shipment is forbidden on passenger aircraft).
- The lithium battery mark is required for Section II shipments and for certain Section IB shipments, but for Section IA the Class 9 label and the Cargo Aircraft Only label are the controlling requirements.
The shipper's reliance on the lithium battery mark alone reflects a Section II mindset applied to a Section IA shipment - a classic acceptance trap.