（A question on Nickel-metal hydride Batteries.）
Q.
The shipper of a nickel-metal hydride battery powered temperature controlled storage device desires to have the battery left activated throughout the trip. We have checked SP A123 where it says the device must be protected from unintentional activation. The shipper claims that the intent of the rule is assumed to prevent unintentional activation but does not preclude intended activation for providing temperature controlled storage.
We checked SP A123, and it also says that the battery must be disconnected. If the battery must be disconnected, obviously, the device will not be functioning. Please advise how should we treat this shipment.
Furthermore, in checking the blue pages (DGR 4.2) we came across UN3496 Batteries, nickel-metal hydride where we noticed a reference to SP A199 which is worded: “The UN number UN3496 is only applicable in sea transport. Nickel-metal hydride batteries or nickel-metal hydride battery-powered devices, of a dangerous evolution of heat are not subject to these Regulations provided they are prepared for transport so as to prevent:
(a) a short circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals, or in the case of equipment, by disconnection of the battery and protection of exposed terminals; and
(b) unintentional activation.
The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is used.”
From this language, we take that UN3496 Batteries, nickel-metal hydride is not regulated for air transportation and consequently, SP A199 is also not applicable to UN3496 when forwarded by air. If so, it does not preclude us from forwarding our temperature controlled storage carried on the aircraft in an activated state. Please provide guidance. (31 Jan 19)
A.
Nickel-metal hydride batteries come under UN3496 Batteries, nickel-metal hydride and Special Provision A199 applies. Referring to SP A199, it says: “The UN number UN3496 is only applicable in sea transport. Nickel-metal hydride batteries or nickel-metal hydride battery-powered devices, equipment or vehicles having the potential of a dangerous evolution of heat are not subject to these Regulations provided they are prepared for transport so as to prevent:
(a) a short circuit (e.g. in the case of batteries, by the effective insulation of exposed terminals, or in the case of equipment, by disconnection of the battery and protection of exposed terminals; and
(b) unintentional activation.
The words “Not Restricted” and the Special Provision number must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is used.”
Since the battery must be disconnected, the device will not be functional at all.
Electronic equipment which need to be in an activated state during the entire duration of the journey for the purpose of temperature control or for data logging, there are other requirements that need to be satisfied.
For details, we refer to “TOPICS” column of our Website. Please refer to the 12th from the top entries titled: “Guidance on the Use and Carriage of Battery-Powered Data Loggers (Feb. 1, 2017).” On Pages 5 and 6 of this Guidance document, you will find “Recommendations on Shipping Active Devices” . According to that Recommendation, there are 5 fields that must be satisfied, namely, (1) the electronic device and its peripherals must meet the radio frequency radiated emissions limits defined in RTCA/DO-160 Enviromental Conditions & Test Procedures for Airborne Equipment; (2) the device is designed with a minimum of two independent means to turn off completely when airborne, (3) the device manufacturer must have submitted complete specification and functionalities of the device; (4) the device must not be capable of generating a dangerous evolution of heat; and (5) the device must not be capable of emitting disturbing signals, such as buzzing alarms or strobe lights, during transport. It is the responsibility of the airline to ascertain that the activated device will not interfere with aircraft navigation or communication systems.rous evolution of heat; and (5) the device must not be capable of emitting disturbing signals, such as buzzing alarms or strobe lights, during transport.
It is the responsibility of the airline to ascertain that the activated device will not interfere with aircraft navigation or communication systems.
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