(Question on certification of State of Charge for lithium batteries effective 01 April 2016.)

Q.
Effective 01 April 2016, lithium ion battery shipments when presented for transport, the State of Charge (SoC) must not exceed 30% of the rated capacity. How can this be ensured by the acceptance staff at time of acceptance? Will there be any indication provided by the shipper in this regard to ensure compliance with the regulations and assure free acceptance? Or what could be the suggested method to check the SoC? To these questions, FAQ responded that there is no requirement for the shipper to specifically prove that lithium batteries shipped as UN 3480 are at less than 30% SoC, or for the operator to somehow verify that the lithium ion batteries are at no more than 30% SoC. The shipper by signing the Shipper’s Declaration for Dangerous Goods is certifying that “I declare that all of the applicable air transport requirements have been met.” This is a legal declaration. This is no different to a shipper stating on the Shipper’s Declaration that the flammable liquid is actually Packing Group II, or that the dangerous goods are as described by the UN number and proper shipping name shown. This was the answer given. While Section IA and IB are covered by a Declaration, how do we verify batteries shipped under Section II where there is no DGD.  (31 Mar 16)

A.
Section II shipments are covered with an AWB made by the shipper. It must carry the words:

“Lithium ion batteries in compliance with Section II of PI 965” which is sufficient proof that the shipper has complied with all the requirements of Section II.


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