Navigating the world of battery transportation can feel like trying to solve a puzzle with pieces that just don’t seem to fit. As the energy transition continues, and with more technologies and industries supporting electrification, there is a need for more batteries. The adoption of electric vehicles (EVs) continues, and more construction equipment, including forklifts and more, is moving away from diesel and propane-powered engines. The use of energy storage, including for both commercial and residential applications, is growing, along with the need for storage to support renewable energy resources.
All these various applications require a multitude of batteries, big, small, in different forms and shapes, and also with different chemistries, weight, and watt-hour capacity. Regulators are playing catch-up with the technologies and markets, which are developing at high speed and carry significant risks as they mature. The requirements are constantly changing, and it’s easy to feel overwhelmed. Utilities and others using batteries need to know how to navigate the issue of applying today’s regulations to the user’s specific needs.
Understanding Battery Transportation Regulations
When it comes to shipping batteries, the U.S. Department of Transportation (DOT) lays down the law. Their regulations are designed to keep everyone safe, and they cover everything from how batteries are packaged to the labels that must be displayed. The DOT has recently published the “Lithium Battery Guide for Shippers” to help companies safely package lithium cells and batteries for transport by all modes, in accordance with the latest international harmonization regulatory requirements.
If you’re looking to ship internationally, this can be a different story, as you’ll also need to be aware of the standards set by the International Civil Aviation Organization (ICAO) and the International Maritime Dangerous Goods (IMDG) code. These organizations have their own sets of rules that are just as crucial to follow.
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1. This battery, placed in a regulatory-compliant container, will be transported by truck. Courtesy: Bluewater Battery Logistics |
The U.S. Hazardous Materials Regulations (HMR) and international regulations are complex and difficult to navigate particularly for those not using them regularly. Your best resource is to work with professionals that are knowledgeable and have extensive experience applying the regulatory requirements while understanding the best practices to enhance safety while reducing unnecessary expenses. For example, even if your batteries are classified correctly, and have all the required labels, you still need to make sure your shipper is trained and certified for hazmat transportation. Additionally, there are a number of innovative packaging alternatives (Figure 1), each having advantages and disadvantages, which the professionals can recommend. The complexity and the high risks involved makes transportation companies with a hazmat focus join forces with battery logistics specialists and their hazmat legal partners to make sure the battery shipments are safe and compliant.
In This Issue
Full issueApplying Shipping Conditions and Requirements
One example of such a group is led by the second-life battery market specialist Bluewater Battery Logistics, which partnered with Hazmat Safety Consulting (HSC, see sidebar). Bob Richard, HSC’s president, served as the deputy associate administrator for the Pipeline and Hazardous Materials Safety Administration (PHMSA), the regulatory agency responsible for writing and enforcing the DOT’s Hazardous Materials Regulations. Richard led U.S. delegations to international meetings and served as the chairman of the U.N. Sub-Committee of Experts on the Transport of Dangerous Goods that is responsible for maintaining the U.N. Model Regulations including lithium battery regulations.
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Bluewater Partnership with HazMat Consulting Bluewater Battery Logistics in December 2024 announced a partnership with Hazmat Safety Consulting, a Virginia-based company that works with U.S. and international regulators and shippers. The collaboration aims to enhance safe and U.S. Department of Transportation (DOT)-compliant battery redistribution and recycling services across the U.S. Regulatory development has been reactive trying to keep up with the rapid technological advancements in the battery manufacturing industry. The Bluewater partnership with Hazmat Consulting will help freight haulers more effectively navigate the complexities of compliance and safety in an evolving regulatory landscape. “Battery technology is advancing rapidly, and with it comes a myriad of challenges in applying regulations in a real world,” said Ben Firestone, CEO of Bluewater, headquartered in Los Angeles, California. “Our partnership with HazMat Consulting provides our clients with the top expertise needed to stay safe and compliant while optimizing their battery management strategies.” Bluewater through the partnership aims to offer enhanced lifecycle management solutions, ensuring that clients can maximize the value of their battery assets while adhering to safety and transportation regulations. “With over 100 MW of energy storage systems decommissioned and recycled, Bluewater is trusted by leading companies in the utility-scale energy storage space,” said Firestone. “This partnership will further strengthen our position in the market and deliver unparalleled value to our customers.” |
“When shipping lithium batteries, it is essential to understand why a regulation is written and how to practically implement it into your company,” said Richard. “These regulations are dynamic and continually changing. HSC can help to identify compliance issues—before they become a problem.”
There’s a significant difference between new batteries, end-of-life batteries, and those determined to be damaged or defective. Recalled batteries pose a significant challenge. New batteries usually have fewer restrictions, while end-of-life batteries and damaged batteries require more stringent handling due to their potential hazards. Further on, batteries headed for recycling may have different sets of requirements (limited state of charge, marking and labelling, packaging, etc.) compared to those batteries headed for their second-life applications, or for repair or refurbishing for their original application.
Handling intact batteries might seem straightforward, but what happens if a battery is defective? You’ll need to take extra precautions. Defective batteries can leak harmful electrolyte, or worse—we’ve all seen powerful fires following a thermal run-away event involving compromised or defective batteries. It’s vital to have a clear understanding of how to package and label them to minimize risks and potential enforcement actions by regulatory agencies such as PHMSA.
Packaging and Labeling Guidelines
Proper packaging is not just a formality; it’s a necessity. Most battery shipments must meet specific U.N.-approved packaging requirements to ensure that they survive the journey intact, without posing a health and safety risk. Getting packaging guidance that is specific to the weight, power output, condition, and chemistry of your batteries is essential, especially for larger or heavier batteries for which the regulations require extra measures to prevent thermal events (Figure 2) during transportation.
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2. This truck transporting end-of-life lithium-ion batteries overturned on Interstate 15 between Barstow, California, and Las Vegas, Nevada, in summer 2024, prompting lawmakers to call for stricter regulations on the transport of lithium-ion batteries. Courtesy: Bluewater Battery Logistics |
Labeling is equally important. Every package must display the correct hazardous materials labels (Figure 3), along with the appropriate U.N. markings. This isn’t just about compliance; it’s about communicating the risks to people handling the shipment, including emergency responders. Accurate shipping papers are crucial too, detailing the contents, handling instructions, and emergency contact information. This ensures that if something goes awry, everyone knows how to respond.
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3. These lithium batteries are being transported in boxes that clearly label the contents to alert shippers about the materials inside. Courtesy: Bluewater Battery Logistics |
Employee Training and Safety
One of the most effective ways to ensure safe and compliant shipping is through proper training, especially hazmat training. Getting detailed, clear and straightforward instructions tailored to your everyday operations for your team members plays a critical role in the shipping process. Simply having access to the full-blown document with DOT regulations is not equipping them with the right knowledge, there is a need for a clear set of instructions.
Bluewater provides customers with access to customized training materials created to help the staff stay informed about the latest regulations and best practices. Generic online or classroom courses that are not customized to the operations are typically ineffective.
Establishing a clear communication channel for reporting incidents or near-misses is also crucial and consistent with establishing a healthy corporate safety culture. It empowers your team to take immediate action and learn from any challenges they face.
Understanding the regulations governing battery transportation is essential for the safety of your team, the public, your customers, and the environment. By being informed and compliant, you can avoid costly fines, litigation, and insurance rate increases. The full set of shipping capabilities and legal expertise of your battery logistics partner needs to include the practical knowledge and expertise of applying the changing regulations in the rapidly developing battery manufacturing and logistics space.
—Maxim Khabur is director of Marketing at Bluewater Battery Logistics, a U.S. operator on the second-life battery market. He also has been chairman of the Advanced Energy Council, representing a group of companies that are members of MHI, a materials handling industry association.
