(All lithium batteries must pass the UN Test. Please teach us how to identify them.)

Q.
We understand all lithium batteries must meet the criteria of UN Test 38.3. How about lithium batteries produced prior to the announcement of the UN rule. Is there a UN test facility where batteries are brought in to undergo the UN tests? How can we identify whether the batteries have passed the UN tests? (30 Jun 13)

A.
As stipulated in DGR 3.9.2.6. (a) each lithium cell and battery must undergo the test requirements of UN Manual of Tests and Criteria, Part III, Subsection 38.3. There is no exception. Those made prior to the rule are no exception. The test is not done at any dedicated UN test facility but is done by each lithium battery manufacturer following the requirements of the UN test which ranges from Test 1 through Test 8. Furthermore, as stipulated in DGR 3.9.2.6 (e) 1. through 9 and the following Notes, the production must be carried out under a quality management program. This quality management program is also left to each manufacturer to follow the stipulations laid down by UN.

Since, the production of lithium batteries reach an enormous number, and since there are numerous manufacturers worldwide, it is found difficult to have the cells/batteries carry a Test Marking or have a Test Certificate issued. UN ICAO is still studying ways and means to set up an identification program but it may be very difficult. As the UN test itself cover various qualifications, and the number of cells/batteries used in the test are enormous, only established manufacturers are capable to absorb the burden. As long as the cells/batteries are produced by noted firms, it is therefore considered safe. The transport of dangerous goods is based on mutual trust.

Effective 1 January 2013, UN 38.3 has been amended. Until 1 January 2014, cells/batteries manufactured under the @revious criteria may be shipped but after 1 January 2014, only those manufactured based on the newly amended 38.3 may be shipped.


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