The HM-125N “harmonization rule” has been published by PHMSA (DOT) after being delayed for months. This rule has many changes to all HM regulations. There are some notable changes to the lithium battery regulations, most of which are simply harmonizing DOT regulations with international Air regulations.
Some of these changes are effective immediately, some are mandatory after December 31, 2018 and others are mandatory after December 31, 2019, so it is extremely important to review the changes if you are shipping lithium batteries in any form.
Here is a summary of the lithium battery changes:
- The new lithium battery mark, used for small batteries, replaces the wordy US requirements in § 173.185(c)(3) and the ICAO lithium battery handling label. The mark, already in use internationally, has minimal wording. Instead, the mark is to be supplemented with the UN number(s) of the material contained within (UN3480, UN3481, UN3090, UN3091), as well as a telephone number of someone who is familiar with the contents of the package.
- The new Class 9 label for lithium batteries has been adopted. The label includes battery icons on the lower portion of the label. Note if packages contain lithium batteries requiring the label as well as other Class 9 materials, both the Class 9 and Class 9 lithium battery label will be required.
- As a result of increased hazard communication harmonization, the safety document accompanying small and medium battery shipments has been eliminated.
- New “Consignment” rule has been implemented. The exception to mark packages containing up to 2 batteries or 4 cells installed in equipment remains. But now the number of packages per consignment eligible for the exception are limited to 2. Thus if no more than two packages without the lithium battery mark are offered per consignment, no marking is required on either package. But if 3 packages are offered in a single consignment, all 3 packages must be marked. This exception limitation exists now in all modes.