(May we pack UN3090 and UN3091 in the same outer packaging? )
Q.
We need your guidance on packaging Lithium Metal Batteries.
UN3090 Lithium metal batteries PI 968 Section II must not be packed in the same outer packaging with other dangerous goods. Would UN3091 Lithium metal batteries contained in equipment PI 970 Section II be also considered as “other dangerous goods” and cannot be packed together with UN 3090? Please give us your guidance. (30 Nov 21)
A.
In Additional requirements – Section II of PI 968 Section II there is a rule saying: ”Cells and batteries must not be packed in the same outer packaging with other dangerous goods.” ”Other dangerous goods” is interpreted as articles and substances with a different UN number. UN3090 and UN3091 are two different UN numbers therefore they cannot be packed in the same outer packaging. Howeever, the same Lithium metal battery is either packed by itself or installed in an equipment. Even though the UN number is different they are the same Lithium Metal Battery in a different form. Some airlines stick to the rule and reject the shipment, while other airlines accept considering they are the same object although the UN number may differ. There will be no problem if it can be carried to the final destination witout interline transfer. When an interline transfer is needed, problems occur from the difference in interpretation.
Section II will be completely deleted from PI 965 and PI 968 effective from January1, 2022 and cells and batteries which had been transported as Section II will have to be transported as Section IB. The segregation clause pertaining to “other dangerous goods” will also be deleted, and the segregation rule for Section IB will apply. The rule is Section IB must not be packed with Class 1 ecept 1.4S, Div. 2.1, Class 3, Div. 4.1 and Div. 5.1.

There is a transition period until March 31, 2022 during which period batteries may be transported as Section II however the airlines would probably not support. There is only one month to January 2022. The elimination of Section II of PI 965 and PI 968 is said to be from mis-use of the slack Section II rules widely practiced in Asia. As a conclusion the choice is: (a) permit APIO up to March 31, 2022 provided there is no interline transfer, or (b) start rejecting APIO now, until Dec. 31, 2021.

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