Damaged lithium ion batteries under an operator restriction
An airline's cargo sales team is offered six pallets of UN 3480 lithium ion batteries for a passenger flight from Seoul to Los Angeles. Each pallet holds 200 batteries rated at 3.7 V and 50 Wh, giving 600 kg net for the consignment. The batteries are returns from a consumer recall: 15 cells are visibly swollen, two have corroded terminals, and the forwarder has packed them in UN specification fibreboard boxes under PI 965 Section IA. The Shipper's Declaration states 'UN 3480, Lithium ion batteries, 9, PI 965 Section IA, 600 kg net, 6 pallets' and the forwarder says the 30% state-of-charge rule does not apply because this is Section IA. The operator's dangerous goods manual includes a variation: 'UN 3480 and UN 3090 are forbidden on passenger aircraft; cargo aircraft only, and only with prior written approval.' The forwarder has no approval letter.
1. Can the consignment be accepted on the passenger flight as offered? Address the condition of the batteries, the operator variation, and the state-of-charge claim.
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No. Three separate obstacles apply. First, the swollen cells and corroded terminals are evidence of damaged/defective lithium ion batteries. Damaged or defective cells/batteries are forbidden for air transport unless the applicable damaged/defective approval has been obtained; they cannot be shipped as ordinary UN 3480 under Section IA. Second, the operator variation expressly forbids UN 3480 on passenger aircraft and requires cargo aircraft with prior written approval. The forwarder has no approval, so the passenger flight is not available. Third, the state-of-charge claim is wrong: the 30% SoC limit for UN 3480 applies to Section IA as well as the other PI 965 sections; Section IA does not exempt the shipment. The offer must be refused.
2. What must the forwarder and operator do before any air transport could take place?
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Before any air movement: isolate the 15 swollen cells and two corroded-terminal batteries; do not offer them for transport without the damaged/defective approval. For the remaining batteries, verify the UN 38.3 test summary, the PI 965 Section IA packaging, and evidence that the state of charge is ≤30%. Remove the passenger-aircraft option; obtain the operator's prior written approval for cargo aircraft and prepare the shipment as cargo aircraft only with the CAO label. A new DGD is required with the correct net quantity and PI section, and the operator must check state variations for the origin, transit and destination. Acceptance staff must also verify that the shipper's DG training is current and that the emergency contact is 24-hour.
3. If the damaged batteries are removed and the remaining batteries are shipped, what documentation and marking changes are needed?
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After removal, the DGD must no longer state 600 kg net; it must state the actual net quantity of the remaining batteries and must identify PI 965 Section IA. The packages must show the Class 9 label and, where required by the applicable PI section, the lithium battery mark. The 'Cargo Aircraft Only' label must be applied, and the operator's approval reference should be attached to the file. The shipper should also provide a statement or evidence of ≤30% state of charge. If any battery is later found damaged, the shipment must stop and be re-assessed under the damaged/defective rules.