TT Talk - Spotlighting Lithium-ion risks

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Lithium batteries was a topic that TT Talk covered in February 2022 in recognition of emerging concerns over incidents through the global supply chain. One such concern was a shift away from air transport towards maritime and road. Over the last eight months, such fears appear to have materialised with an increasing number of incidents recorded through other modes of transport.

In the February edition, the complexities of lithium batteries were explored. That article discussed the various types of battery shipped in goods or with goods, and clarifying the applicable UN numbers for typical lithium battery cargoes. What became apparent was just how complex this commodity can be. This recognition led to TT collaborating with UK P&I Club and Brookes Bell to undertake a more in depth study.

What became apparent was just how complex this commodity can be

The result is a whitepaper focused on three primary aspects:

  • the science behind lithium batteries, what they are, the key components and their respective functions, what happens in terms of charging, discharging and holding charge. This section also addresses the hazards associated with lithium batteries and the safety systems typically available.
  • the regulations that underpin the transport of lithium batteries, with a particular focus on the maritime supply chain. This section considers the requirements around construction and statutory testing, classification of lithium battery cargoes (including electric vehicles – EV) and the various applicable UN numbers and Special Provisions (SP).
  • fire risk and emergency response. Many industry bodies have highlighted the intensity at which lithium batteries burn once ignited; typically burning at over 400°C with a sustained flame, such fires are challenging to extinguish, and re-ignition is a real risk.

Homing in on firefighting

CO2 and foam are entirely ineffective as firefighting mediums with lithium battery fires; significant amounts of water currently appear the most effective. Electrocution remains a further, often forgotten risk when fighting such fires. 

Beyond the challenges of extinguishing a fire, particularly on board a ship (whether container or ro-ro), there are other concerns. A prominent issue is that smoke, being an initial visible sign of a developing fire, comprises potentially highly toxic vapours and fumes. Further, some of these are denser and some less dense than air, so the traditional rule of ‘go in low’ for firefighters does not apply.

Additional concerns have been raised about effective decontamination of clothing and equipment following firefighting activity. The combination of water and toxic vapours, such as hydrogen fluoride, can react to form hydrofluoric acid. Both are highly irritating and corrosive, and can be fatal if inhaled, swallowed or skin is exposed. Thus, careful consideration must be given to processes for decontamination and handling post-incident – another challenge at sea.

Key whitepaper takeaways

The joint paper outlines initial ‘calls to action’ in a number of respects, impacting not simply those tasked with moving this commodity and the respective regulators, but most importantly any industries involved in manufacturing or using this increasingly crucial power source, who enter the goods or related products into the freight supply chain.

 The joint paper outlines initial ‘calls to action' [impacting] any industries involved in manufacturing or using this increasingly crucial power source

Test Certificates

Although there is a requirement for manufacturers to test batteries and for manufacturers and subsequent distributors to make the test summary available, there is at present no explicit requirement on shippers to submit either the test summary or any document issued by an independent laboratory when consigning lithium-ion batteries for transport. This is despite the fact that such testing is a requirement for exemption of certain types of batteries under SP 188. Without this documentation, the carrier cannot verify whether the requirements have been satisfied.

Classification of lithium-ion powered electric vehicles

At present, classification UN 3171 covers battery-powered vehicles and equipment. This covers all electric vehicles, including Li-ion powered EVs, whereas SP388 specifically excludes equipment (other than vehicles) powered by lithium-ion batteries, which are assigned the respective UN numbers for the batteries they contain. This appears an anomaly. In view of the distinct hazards associated with lithium-ion batteries and the rapid increase in volume of manufacture and transport of lithium-ion powered EVs, a separate UN number for such EVs would provide greater clarity, with specific requirements for declaration and documentation (eg. state of charge, battery chemistry, type of battery, capacity and/or details on any safety system in place). Happily, this will shortly have some scrutiny at the UN Sub-Committee of Experts on the Transport of Dangerous Goods based on a submission by International Air Transport Association (IATA), the air transport industry trade association.

Exemption for EVs carried on ro-ros and car carriers

At present, SP 961 excludes EVs carried on ro-ros and car carriers from the requirements under UN 3171. Because of this, carriers do not generally have a list of all EVs on board or their respective locations. Revoking this exemption would allow carriers to plan stowage locations and the monitoring of EVs during the voyage in detail, with a view to developing early detection, evacuation and/or firefighting procedures.

Mandatory markings for EVs

At present, there is no requirement for EVs to be identified either during consignment procedures or by external markings on the vehicle. Mandatory marking would assist stowage and emergency response.

Preventing short circuits

Batteries are required to be packaged in such a way as to prevent short circuit, but there is no explicit requirement as to how this may be achieved, such as by covering the terminals.

State of Charge (SOC)

When shipping Li-ion batteries by air, IATA regulations specify a maximum SOC of 30% of their rated capacity. No such SOC criteria are currently in place for transportation by sea or other surface modes. It should be noted that EVs, for example, are increasingly being transported internationally by rail.

Battery condition on loading

Current regulations do not take into consideration that a significant proportion of batteries are transported immediately after having been used or charged, as is the case for EVs having been driven onto a ro-ro or car carrier. Enhanced risk detection procedures may include checks before loading on SOC and battery condition/temperature.

Damaged or defective batteries

Regardless of ‘end of life’ management, batteries that are known by the consignor to be damaged or defective clearly can no longer conform to their design safety testing. Such consignments therefore may present unforeseeable levels of risk. Current regulations contain stringent packing requirements for shipments that are considered high risk, but do not specify how such high-risk shipments are identified and differentiated from ‘low-risk’ damaged or defective batteries.

The issues are global and impact everyone involved with Li-ion batteries; they need urgent cross-industry engagement.


If you would like further information, or have any comments, please email us, or take this opportunity to forward to any others who you may feel would be interested.

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Peregrine Storrs-Fox

Risk Management Director