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Before offering a hazardous material to an air carrier for shipment, the Hazardous Materials Regulations require YOU, the shipper, to properly classify, package, mark and label the package to identify the hazard.
When shipping hazardous materials (e.g., lithium batteries or battery powered devices, aerosols, oxygen cylinders) or flammable liquids (e.g., perfumery products or alcoholic beverages) please follow these steps to ensure your package is correctly packed and marked:
Step 1: The Safety Data Sheet (SDS) is a good starting point for determining if an item you are shipping might be a hazardous material. Typically, you can obtain an SDS from the manufacturer of the products that you plan to ship by air, and check the transportation information section. Pay particular attention to the specific information that pertains to shipments by air.
- A hazardous material is defined as a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see 49 Code of Federal Regualtions (CFR) § 172.101), and materials that meet the defining criteria for hazard classes and divisions in Part 173 of [the Hazardous Materials Regulations].
Step 2: If you determine that an item is a hazardous material, the FAA recommends that you perform a needs assessment analysis to determine which employees at your company will be performing a hazmat function and identify the level of training that is needed by the regulations.
Step 3: For most employees, training will include general and security awareness, safety, and function-specific training. Under the 49 CFR, a hazmat employee is required receive recurrent training every three years.
- The lCAO Technical Instructions provide that the recurrent hazardous materials training requirements prescribed in Part L, Chapter 4, Section 4.2.3, "must take place within 24 months of previous training to ensure knowledge is current."
- Hazmat employee is a person employed by a hazmat employer, or person who is self-employed, and who directly affects hazmat transportation safety including a person who:
- loads, unloads, or handles hazmat;
- designs, manufactures, fabricates, inspects, tests, reconditions, repairs, modifies, marks, or otherwise represents packagings as qualified for use in the transportation of hazmat;
- prepares hazmat for transportation;
- is responsible for safety of transporting hazmat; or
- operates a vehicle used to transport hazmat.
Step 4: Have a trained employee look up the material in the Hazardous Materials Table to determine the authorized quantities permitted to be shipped, labels required, and the allowable packaging as per the 49 CFR Part 173 and the packing group.
Step 5: Determine the quantities and corresponding packaging requirements for your shipments. Depending on the packing group assigned to the hazardous material, UN-Specification packaging may be required.
- The Packing Group is a grouping according to the degree of danger presented by hazardous materials. The performance level identifies the performance standard to successful testing of the packaging:
- X – For packaging meeting Packing Group I, II and III test. (Packing Group I – Great Danger)
- Y – For packaging meeting Packing Group II and III test. (Packing Group II – Medium Danger)
- Z – For packaging meeting Packing Group III test. (Packing Group III – Minor Danger)
Step 6: If UN-Specification packaging (PDF) is required, read the package closure instructions carefully and obtain all the materials listed in instructions, such as tape, zip ties, poly bags, etc. Be sure to follow the information closely. Packages meeting UN specifications are tested with the materials listed in the closure instructions. Any variation from the manufacturer's instructions is a violation and could compromise the integrity of the package.
Step 7: Once you have the proper packaging, obtain the appropriate hazard communication, i.e., markings, labels, and shipping paper/shippers declaration. Generally, the Proper Shipping Name, the UN Number, and the shipper or consignees name and address are required to be marked on the package on the same surface as the label.
Step 8: Mark and label the package.
Step 9: If you are using a combination package, place the material in its inner packaging in accordance with the closure instructions. Then place the inner packaging in its authorized outer packaging and seal the package in accordance with the package closure instructions.
Step 11: Your package is ready to be shipped.
Step 12: Keep the Shipper's Declaration on file for a period of two years.