(Question on Test Summary requirement for Lithium Battery shipments.)
Q.
As per DGR 3.9.2.6.1 (g) newly introduced with the 60th Edition DGR which reads: (g) manufacturers and subsequent distributors of cells and batteries manufactured after 30 June 2003 must make available the test summary as specified in the UN Manual of Tests and Criteria, Part III, subsection 38.3, paragraph 38.3.5. This test summary must be made available from 1 January 2020.” As a manufacturer, we intend to publicize our test summary on our website. Please advise if this is acceptable.  (30 Apr 19)
A.
Please refer to our Website and click “2019 Lithium Battery Guidance including Test Summary, Revision 1 (Dec.12.2018).” On Page 4 towards the end of the page, there is a new rule on Lithium Battery Test Summary which reads:

“Lithium Battery Test Summary – effective 1 January 2020, manufacturers and subsequent distributors of cells or batteries and equipment powered by cells and batteries manufactured after 30 June 2003 must make available the test summary as specified in the UN Manual of Tests and Criteria, Revision and Amend. 1, Part III, sub-section 38.3, paragraph 38.3.5.”

The entry continues to a Note which is reproduced below:
“Note: The requirement is for the manufacturer and subsequent distributor to make this test summary available. There are numerous ways this can be achieved, such as by listing the applicable summary document on the company website. There is no expectation for the shipper/distributor to provide paper copies with each consignment containing lithium batteries. The supply chain are encouraged to make use of technology to facilitate the availability of the test summary.”

On Page 5 of the Guidance, the 10 entries required on the test summary is listed. Further on Page 21 from Part 4 are 10 Q and As (from A to J) pertaining to the test summary, plus 3 samples of test summaries starting from Page 23.

It is desired that instead of providing printed test summaries for each consignment, a simple but a positive way of providing the test summary elements through the use of technology such as the website is encouraged..

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