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Update on Changes in IMDG Code and ADR/RID Dangerous Goods Regulations

Update on Changes in IMDG Code and ADR/RID Dangerous Goods Regulations. Marco Ottaviani Dangerous Goods Safety Adviser Expert in Regulatory, Environmental, Safety and Transport Issues Vicenza Area, Italy marco.ottaviani1@gmail.com. Marco Ottaviani Dangerous Goods Safety Adviser.

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Update on Changes in IMDG Code and ADR/RID Dangerous Goods Regulations

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  1. Update on Changes in IMDG Code and ADR/RID Dangerous Goods Regulations Marco Ottaviani Dangerous Goods Safety Adviser Expert in Regulatory, Environmental, Safety and Transport Issues Vicenza Area, Italy marco.ottaviani1@gmail.com

  2. Marco Ottaviani Dangerous Goods Safety Adviser Changes Common to All Transport Modes • Batteries are articles • No packing group assigned • Specific packaging performance level (e.g., PG II) is identified in applicable packing instruction • Applies to UN, IMDG Code, IATA, ICAO ADR 2015

  3. Marco Ottaviani Dangerous Goods Safety Adviser ADR 2013 vs 2015 Blue = amended Red = new

  4. Marco Ottaviani Dangerous Goods Safety Adviser ADR 2015 Use of Large Packaging for Lithium batteries LP 903 (new batteries) LP 904 (D&D batteries) (Lack of LP for batteries for recycling or disposal) "Large packaging" means a packaging consisting of an outer packaging which contains articles or inner packagings and which Is designed for mechanical handling Exceeds 400 kg net mass or 450 litres capacity but has a volume of not more than 3 m3

  5. Marco Ottaviani Dangerous Goods Safety Adviser ADR 2015 • Special Provision 636b (as amended) • I. Up to the intermediate processing facility, lithium cells and batteries collected and transported for disposal or recycling: • with a gross mass of not more than 500 g each • small excepted (SP 188) • whether or not contained in equipment • together with or without other non-lithium cells or batteries, • Are not subject to the other provisions of ADR including • Special Provision 376 (D&D batteries) and • paragraph 2.2.9.1.7 (general requirements of lithium batteries) • If they meet the following conditions: • Comply with packing instruction P909 (except short-circuit protection); • A quality assurance system to ensure that the total amount of lithium cells or batteries per transport unit does not exceed 333 kg; • Packages are marked “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING” as appropriate.”

  6. Marco Ottaviani Dangerous Goods Safety Adviser ADR 2015 • Damaged or Defective Lithium Batteries • ADR 2013 • Special Provision 661 - Packaging conditions and authorization from National Competent Authority • Multilateral Agreement 259 (in countries which signed it) - Voluntary application in advance of SP 376 + PI 908 or LP 904 • ADR 2015 • Special Provision 376 + PI 908 or LP 904 • Authorization of Competent Authority required for batteries in high risk conditions only

  7. Marco Ottaviani Dangerous Goods Safety Adviser IMDG Code 2015 • Large Packaging for lithium batteries • LP 904 • New Special Provision and Packing Instruction for lithium batteries “transported for disposal or recycling” • SP 377 and P909: Always shipped as Class 9 dangerous goods! • May also use P903 or SP 188 • New Special Provision and Packing Instructions for damaged or defective lithium batteries • SP 376 and P908 or LP 904: Always shipped as Class 9 dangerous goods!

  8. Marco Ottaviani Dangerous Goods Safety Adviser IMDG Code 2015 • New Special Provision 377 for lithium batteries “transported for disposal or recycling” • Lithium ion and lithium metal cells and batteries and equipment containing such cells and batteries transported for disposal or recycling, either packed together with or packed without non-lithium batteries, maybe packaged in accordance with packing instruction P909 …..

  9. Marco Ottaviani Dangerous Goods Safety Adviser IMDG Code 2015 • Special Provision 376 – Damaged or Defective Lithium Batteries

  10. Marco Ottaviani Dangerous Goods Safety Adviser Damaged or Defective Lithium ion Batteries? 10

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