(May we interpret Section IB of PI 965 for Lithium ion batteries as an exemption of Section IA?)

Q.
We are to ship PI 965 Section IA Lithium ion batteries as dangerous goods. Is it correct to interpret Section IB as an exemption of Section IA? (31 Oct 13)

A.
No, it is totally incorrect. Section IA, IB and II are all “dangerous goods.

They are not exempted. The definition of “Exemption” is as spelled in DGR 1.2.6 where dangerous goods may have to be transported to combat a natural disaster such as an earthquake or tsunami. There would be a need to deviate from the regulations. Such is an “exemption”. The term “exemption” is totally foreign to describe Section IB. Section IA covers lithium-ion cells exceeding 20Wh and lithium-ion batteries exceeding 100Wh. Section IB and II refers to cells not exceeding 20Wh, and batteries not exceeding 100Wh.

When you go beyond the quantity limitations you must apply Section IB and if the quantity is within limits, you apply Section II. In all cases, they are all “dangerous goods”. They are not “exempted”.


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