eBook Pb-NiCD-NiMH-NaNiCl Batteries 2023

Pb, NiCd, NiMH, NaNiCl Batteries Transport and Packaging Instructions Multimodal approach Lead-acid Batteries Nickel-Cadmium Batteries Nickel-Metal Hydride Batteries Sodium-Nickel Chloride Batteries 2023 MARCO OTTAVIANI

Copyright © 2023 This instruction manual has been prepared by Dr. M. Ottaviani. Publishing and delivery in partnership with Hyper srl via Cardinal Bessarione 5b – 30173 Venice (Italy) tel.: +39 041976896 e-mail: info@hyperedizioni.com http://www.hyperedizioni.com Finished on January 2023 All rights reserved ©. No parts of this publication can be reproduced without the express editor’s authorization. Even though the editor and the author have paid maximum attention to ensure accuracy, they do not accept any responsibility in the case of errors or omissions.

Table of Content Introduction 9 1. International Transport Regulations 11 1.1 How to use this instruction manual 13 1.2 Definitions 17 1.3 General requirements 19 1.4 Packaging 21 1.4.1 Table with Packaging Codes 22 1.4.2 Table with IBC Codes 23 1.5 Marking and Labelling 25 1.6 Documentation 27 1.7 Special Provisions 31 1.8 Packing instructions 33 1.9 Transport Mode specific requirements 35 1.9.1 ADR - Exemption for quantity carried per transport unit 35 1.9.2 IMDG - Nickel-Metal Hydride batteries restrictions in maritime transportation 35 1.9.3 IATA - Restrictions of Portable Electronic Devices (PED) Containing Batteries 36 1.10 Training requirements 37 1.11 Batteries in vehicles 39 2 Shipping Modes Summary Sheet 41 List of Summary Sheets 43 2.1 LEAD-ACID BATTERIES 45 2.1.1 NEW BATTERIES 45 2.1.1.1 AUTOMOTIVE BATTERIES 45 2.1.1.1.1 Floated UN 2794 46 2.1.1.1.2 Non spillable UN 2800 48 2.1.1.1.3 Not regulated 50 2.1.1.2 INDUSTRIAL BATTERIES 53 2.1.1.2.1 Floated UN 2794 54 2.1.1.2.2 Non spillable UN 2800 56 2.1.1.2.3 Not regulated 58 2.1.2 ELECTROLYTE UN 2796 60 2.1.2.1 Fully regulated 60 2.1.2.2 Limited quantities 62 2.1.3 WASTES 64 2.1.3.1 Batteries 64 2.1.3.2 Uncleaned empty containers 66 2.2 NICKEL-CADMIUM BATTERIES 69 2.2.1 NEW BATTERIES 69 2.2.1.1 Floated UN 2795 70 2.2.1.2 Non spillable UN 2800 72 2.2.1.3 Not regulated 74 2.2.2 ELECTROLYTE UN 2796 76 2.2.2.1 Fully regulated 76 2.2.2.2 Limited quantities 78 2.2.3 WASTES 80 2.2.3.1 Batteries 80 2.2.3.2 Uncleaned empty containers 82 2.3 NICKEL-METAL HYDRIDE BATTERIES 84 MARITIME RESTRICTION 2.4 SODIUM-NICKEL CHLORIDE BATTERIES 86 2.4.1 NEW BATTERIES 86 2.4.1.1 Cells 86 2.4.1.2 Batteries 88 2.4.2 WASTES 90 2.4.2.1 Cells 90 2.4.2.2 Batteries 92

Foreword When intended for transport, several batteries technologies are regulated as Dangerous Goods by the United Nations Transport Organisation and other national transport authorities. This regulation is being permanently adapted to take into consideration the evolution of the technologies. Batteries benefit of a growing market and multiple new usages and applications are constantly proposed to the end users. Battery technology innovation and development helps an increasing number of technicians and engineers to design new equipment powered by automonous sources of energy such as batteries. The necessity for an increasing number of economic actors to respect the UN Dangerous Goods Regulation requires modern communication tools to inform the shippers of batteries about their duties and responsibilities when offering them for transport. The aim of this manual is to offer a simple and visual means to access the UN Regulation via a modern multimedia communication tool. Following a first manual covering the Lithium ion and Lithium metal batteries, this second manual is covering the Lead-acid, Nickel Cadmium, Nickel Metal Hydride and Sodium-Nickel chloride batteries. The regulation is presented in a summarized format covering ground, air and maritime transportation modes. ln a page opposite the various regulations, the packaging and labelling instructions are illustrated to facilitate the implementation of the transport regulation as well as the packaging and labelling requirements by the shipper of batteries. The objective is to offer access to the UN Transport Regulation to the largest number of interested parties in order to make them aware of their duties and responsibilities when shipping batteries according the UN regulation. We thank Dr. Marco Ottaviani for preparing this exhaustive document with the most updated information and Emanuele Fanizzi, the Editor, who has accepted to translate the information into modern multimedia tools accessible to the largest number of users. Brussels, January 2023

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9 Introduction The complexity of the International Dangerous Goods Transport Regulation for Batteries requires an increasing attention from those who are shipping these batteries. Non-Lithium batteries are classified as “Class 4.3” and “Class 8 ” Dangerous Goods in accordance with United Nations Recommendations on the Transport of Dangerous Goods Model Regulations The regulations may frequently change anyway depending on the transport model utilized. This Manual is aimed at delivering basic information to those who are not yet familiar with these International Dangerous Goods Transport Regulations. The manual is divided into two parts. Part 1 is summarizing the main regulation requirements for road, sea and air transport. Part 2 contains 22 Summary Sheets where the different transport modes requirements are summarized in one page. On the opposite page, an illustration of the packaging instructions is offered to the reader and presented with illustrative examples to guide the reader. The Manual is organised according to the UN Number of non-lithium batteries, considering "new" and "waste" batteries, the “quantities” of batteries that are shipped, and the separate shipping of electrolyte. This manual is only a guide to assist the reader in preparing non-lithium batteries shipments for transportation by road, sea and air. It doesn’t replace any of the regulations manual that are applicable to the shipment of lithium batteries. If you have any comment on the content of this Manual, we would be pleased to take them into consideration for any further improvement of its content and its practical use.

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International Transport Regulations 11 1. International Transport Regulations UN Model Regulations The Recommendations concerning the transport of all type of dangerous goods have been developed by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods with the aim to ensure the safety of people, property and the environment. They are applicable to all modes of transport and are addressed to governments and international organizations concerned with the regulation of the transport of dangerous goods. They are published in the “Recommendations on the Transport of Dangerous Goods—Model Regulations”. Edition applicable ! 22nd revised edition UN Manual of Tests and Criteria UN Manual of Test and Criteria are developed by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods and published as a separate manual in the “Recommendations on the Transport of Dangerous Goods— Manual of Tests and Criteria”. Edition applicable ! Revision 7 Amendment 1 ADR The European Agreement concerning the International Carriage of Dangerous Goods by Road is consistent with the United Nations “Recommendations on the Transport of Dangerous Goods—Model Regulations”. ADR is an Agreement between States and pursuant to European Directive 2008/68/EC is applied at national level in the Member States on the European Union. Edition applicable ! ADR 2023 On a voluntarily base ! ADR 2021 until 30.06.2023 IMDG International Maritime Dangerous Goods (IMDG) Code is prepared by International Maritime Organization - IMO and is consistent with the United Nations “Recommendations on the Transport of Dangerous Goods— Model Regulations”. IMDG Code harmonizes the practices and procedures followed in the carriage of dangerous goods by sea and ensures compliance with the mandatory provisions of the SOLAS Convention (International Convention for the Safety of Life at Sea) and of Annex III of MARPOL (International Convention for the Prevention of Pollution from Ships). Edition applicable ! IMDG Code 40-20 On a voluntarily base ! IMDG Code 41-22 from 1.1.2023 IATA ICAO The International Civil Aviation Organization (ICAO) develops the regulations for the safe transport of dangerous goods by air by any aircraft (including both internal and external carriage) on the basis of the Recomme dations on the Transpo t of D ngerous Goods—Model Regulations. The ICAO regulations are codified in Annex 18 to the Convention on International Civil Aviation and in its Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO – TI’s) and are recognized as the sole authentic legal source material in the air transport of dangerous goods. Edition currently applicable ! ICAO Technical Instruction 2023-2024 edition The International Air Transport Association (IATA) publishes the Dangerous Goods Regulations (IATA DGR) based on the requirements of Annex 18 to the Convention on International Civil Aviation and the associated Technical Instructions for the Safe Transport of Dangerous Goods by Air, published by ICAO. IATA DGR constitute a manual of industry carrier regulations to be followed by all IATA Member airlines. There are certain differences between the IATA and ICAO regulations which stem from operational considerations and result in a regulatory regime which is necessarily more restrictive than the ICAO requirements. The IATA Regulations also incorporate additional material of practical assistance to users. Edition currently applicable ! IATA Dangerous Goods Regulations 2023 – 64th Edition

International Transport Regulations 12 Periods of applications of International Transport Regulations Year 2019 2020 2021 2022 2023 2024 1st July 1st July 1st July ADR 2017 volunt. ADR 2019 volunt. ADR 2021 volunt. Road ADR 2023 1st June voluntarily IMDG Code 39-18 voluntarily IMDG Code 40-20 M e aritim voluntarily IMDG Code 41-22 Air IATA DGR 2019 IATA DGR 2020 IATA DGR 2021 IATA DGR 2022 IATA DGR 2023 IATA DGR 2024 This edition refers to first semester 2023

International Transport Regulations 13 1.1 How to use this instruction manual This manual is designed to provide a quick and effective guide to personnel who needs to prepare a shipment of non-lithium cells and batteries, either new or waste, by road, maritime and air transport modes, as well as battery electrolyte. It consists of two parts. The first part describes and summarizes the regulatory aspects applicable to the transport of lithium batteries, introducing the basic concepts of the transport of dangerous goods, the duties they impose on producers, distributors and users; it also provides a guide to using the manual in order to give to the user the necessary information. In the second parts Summary Sheets are provided for the three modes of transport. This information is condensed into one page. On the opposite page, images and flow charts illustrating how to perform in practice the packaging requirements , guiding the user step by step to prepare the correct shipment, in accordance with the regulation. Producers, distributors, users, waste managers, recyclers, all those who ship batteries new or waste, or that forward them, with or without re-packing, have the obligation to comply with the applicable regulations depending on the different modes: road, maritime and air. It is therefore necessary to know, for each shipment, how to prepare the batteries, which packaging is allowed, how to mark and label packages and which documents to prepare to accompany the shipment. In additions shippers must take into account specific requirements of each transport mode. The provisions applicable in the various transport modes may differ because they are adapted to ensure maximum safety during transport. This means that regulators have introduced special provisions, restrictions and limitations, or other exemptions and exclusions, with the result of making even more complex the regulatory framework for the transport of batteries. There are many types of batteries which differ in the nature and composition of the electrodes materials. This manual contains only non-Lithium batteries classified as dangerous goods for transport regulations. This manual will propose a decision path that, in six steps, allows users to access the information needed to prepare batteries for transport with the appropriate packaging shipping documents, markings, and labels. These six steps are schematically presented in the next flowchart.

International Transport Regulations 14 Step 1 What type of battery are you considering? The first step consists in choosing between the four different electrochemistries considered in this manual: Lead-acid, Nickel-cadmium, Nickel-metal hydride; Sodium-nickel chloride. Start from the List of Summary Sheets, beginning part 2 Step 2 Do you need information on New, Waste batteries or on Electrolyte ? Not D e r : y charged batteries are not classified as dangerous goods, so they have no restrictions, but due to the possibility to be activated by the users adding the electrolyte, this manual give instructions on how to manage acid electrolyte for Lead-acid batteries and alkali electrolyte for Nickel cadmium batteries. These instructions are inside the chapter of the relevant battery type. For NiMH batteries, your search is completed. No other option is proposed, because this battery is restricted only for maritime transportation. Step 3 For lead-acid batteries only, choose automotive or industrial batteries. Step 4 For lead-acid and nickel-cadmium batteries use the flow chart in order to identify if you battery is floated, non spillable or not regulated There are three options for Lead-acid and Ni-Cd batteries: • floated (traditional) • non spillable, (Valve regulated) These batteries have to be qualified according the vibration and pressure test provided by SP 598, A67 for IATA) and can be placed in any position without electrolyte relase. • not regulated (AGM) non spillable batteries that placed at 55 °C, with broken case, demonstrate no leakage of the electrolyte are not subject to to any dangerous goods transport regulation, because they are “dry”. Step 5 You have now selected the specific summary sheet describing how to ship your batteries, new or wastes, electrolyte and uncleaned empty containers and their UN numbers. Furthermore you have the following options: There are two options for Sodium/Nickel-chloride batteries : • Cells (transport of elements)

International Transport Regulations 15 • Batteries (transport of complete batteries) Definition: Cell : a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Battery: two or more cells which are electrically connected together. There are two options for the transport of electrolyte: • Fully regulated • Limited Quantities Step 6 You will find all the transport information in the identified Summary Sheet page, related to your given types of batteries or electrolyte or empty container to be shipped. LEFT page of Summary Sheet: Use the information of the Summary Sheet from left to right, the relevant provisions have been included in the Summary Sheet according to a logical and practical path. The differences in road, maritime and air transport and packaging requirements have been identified by different background colors and highlighted step by step. A white background is used where the provisions are applicable to more than one transport mode. The orange background applies to road transportation, pink applies to maritime transportation and blue applies to air transportation. On the LEFT page, the Summary Sheet contains the following information: Where applicable, a) UN Number, b) Proper shipping Name, c) Class d) Packing Group e) Hazard label f) Prerequisite, conformity to the general requirements g) Special provisions h) Exemption conditions i) Packing instructions j) Authorized packagings k) Quantity and weight limits l) Provisions applicable to road transportation (i.e. tunnel code, transport category, road transport exemptions) m) Marking and handling labels on packagings n) Overpack labels and markings o) Specific transport document required RIGHT page of Summary Sheet: On the opposite page (to the right), pictures illustrate an example of how to practically prepare packaging for shipment: how to protect cells and batteries from short-circuit, verify and use internal and external packaging, labelling and marking of packages.

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International Transport Regulations 17 1.2 Definitions “ADR” means the Agreement concerning the International Carriage of Dangerous Goods by Road. “Approved packagings” means packagings manufactured under a quality assurance programme, which satisfies the competent authority, conform to the prototype which has passed specific tests. “Automotive battery” means any battery used for automotive starter, lighting or ignition power; “Industrial battery” means any battery designed for industrial or professional uses or used in any type of electric vehicle “Battery” means two or more cells which are electrically connected together and fitted with devices necessary for use, for example, case, terminals, marking and protective devices. A single cell lithium battery is considered a "cell”. "Battery pack" means any set of primary or rechargeable cells or batteries that are connected together and/or encapsulated within an outer casing so as to form a complete unit that the end-user is not intended to split up or open. Not : “battery packs”, “modul s” or “battery ass mblies” having the primary function of providing a source of power to another piece of equipment, for the purposes of this manual are treated as batteries. "Button cell" means any small round portable battery or accumulator whose diameter is greater than its height. “Cell” means a single encased electrochemical unit (one positive and one negative electrode) which exhibits a voltage differential across its two terminals. Note: Under the International Dangerous Goods Regulations and the UN Manual of Tests and Criteria, to the extent the encas d electrochemical unit eets the definition of “cell”, it is a “cell”, not a “battery”, regardless of whether the unit is termed a “battery” or a “single cell battery” outside of regulations and the UN Manual of Tests and Criteria . "Consignee" means any person, organization or government which is entitled to take delivery of a consignment "Consignor" means any person, organization or government which prepares a consignment for transport; “IATA DGR” means the International Air Transport Association - Dangerous Goods Regulation "IMDG Code" means the International Maritime Dangerous Goods Code, “Large packaging” means a packaging consisting of an outer packaging which contains articles or inner packaging and which a) is designed for mechanical handling b) exceeds 400 kg net mass or 450 litres capacity but has a volume of not more than 3 m3 "Overpack" means an enclosure used (by a single consignor in the case of Class 7) to contain one or more packages, consolidated into a single unit easier to handle and stow during carriage; "Package" means the complete product of the packing operation, consisting of the packaging and its contents prepared for dispatch. "Shipper” has the same meaning of consignor. “UN Model Regulations" means the UN Recommendations on the Transport of Dangerous Goods Model Regulation published by the United Nations.

International Transport Regulations 18 "Wastes" means substances, solutions, mixtures or articles for which no direct use is envisaged but which are transported for reprocessing, dumping, elimination by incineration or other methods of disposal. Words “shall", "should" and "may": in the International Transport Regulations, the words "shall", "should" and "may" mean that the relevant provisions are "mandatory", "recommendatory" and "optional", respectively.

International Transport Regulations 19 1.3 General requirements 1.3.1 Protection from short circuit Cells and batteries must be protected so as to prevent short circuits. This includes protection against contact with conductive materials within the same packaging that could lead to a short circuit. Examples of protection against short circuits include, but are not limited to: • individual protection of the battery terminals, • inner packaging to prevent contact between cells and batteries, • batteries with recessed terminals designed to protect against short circuits, or • the use of a non-conductive and non-combustible cushioning material to fill empty space between the cells or batteries in the packaging.

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International Transport Regulations 21 1.4 Packaging Dangerous goods shall be packed in good quality packagings. Packagings shall be strong enough to withstand the shocks and loadings normally encountered during carriage, including trans-shipment between transport units and between transport units and warehouses. Packagings shall be constructed and closed so as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure No dangerous residue shall adhere to the outside of packagings during carriage. "Overpack" means an enclosure used to contain one or more packages, consolidated into a single unit easier to handle and stow during carriage; Examples of Overpack: 1. A loading tray such as a pallet, on which several packages are placed or stacked and secured by a plastics strip, shrink or stretch wrapping or other appropriate means; or 2. An outer protective packaging such as a box or a crate; "Package" means the complete product of the packing operation, consisting of the packaging and its contents prepared for dispatch. Dangerous goods shall not be packed together in the same outer packaging or in large packagings, with dangerous or other goods if they react dangerously with each other and cau ( s a e ) : combustion or evolution of considerable heat; (b) evolution of flammable, asphyxiant, oxidizing or toxic gases; (c) the formation of corrosive substances; or (d) the formation of unstable substances. Before being filled and handed over for carriage, every packaging, including IBCs and large packagings, shall be checked to be free from corrosion, contamination or other defects Any packaging which shows signs of weakening, with reference to the approved prototype shall no longer be used or shall be refurbished so that it can pass the tests required for the prototype. Plastic packagings For plastics drums and jerricans, rigid plastics IBCs and composite IBCs with plastics inner receptacles, unless otherwise approved by the competent authority, the period of use permitted for the carriage of dangerous substances shall be five years from the date of manufacture of the receptacles, except where a shorter period of use is prescribed because of the nature of the substance to be carried. Approved packagings: The packs must have passed specific tests and conform to the prototype tested. Packagings shall be manufactured, reconditioned and tested under a quality assurance programme which satisfies the competent authority. Packing groups letter: X for packing groups I, II and III Y for packing groups II and III Z for packing groups III only

International Transport Regulations 22 Shall bear markings which are durable, legible and readily visible, constituted by a sequence of symbols, letters and numbers, i.e.: Not approved packagings: Where packagings which need not meet the requirements of 4.1.1.3 (e.g. crates, pallets) are authorized in a packing instruction or the special provisions, they are not subject to the mass or volume limits generally applicable to packagings (400 kg or 450 L) conforming to the requirements of Chapter 6.1, unless otherwise indicated in the relevant packing instruction or special provision. 1.4.1 Table with Packaging Codes Kind Material Category Code A. Steel removable head 1A2 B. Aluminium removable head 1B2 D. Plywood - 1D G. Fibre - 1G H. Plastics removable head 1H2 Drums N. Metal, other than steel or aluminium removable head 1N2 A. Steel removable head 3A2 B. Aluminium removable head 3B2 Jerricans H. Plastics removable head 3H2 A. Steel - 4A B. Aluminium - 4B ordinary 4C1 C. Natural wood with sift-proof walls 4C2 D. Plywood - 4D F. Reconstituted wood - 4F G. Fibreboard - 4G H. Plastics expanded 4H1 solid 4H2 Boxes N. Metal, other than steel or aluminium - 4N The United Nations packaging symbol Plastic Drum with removable head F p o ac r king groups: I, II, III M G m r a a o x s s s i s m in um kilograms Carriage o So f lids The State authorizing the allocation of the mark Name of Manufacturer Year of Manufacturing (last two digit)

International Transport Regulations 23 "Drum" means a flat-ended or convex-ended cylindrical packaging made out of metal, fibreboard, plastics, plywood or other suitable materials. This definition also includes packagings of other shapes, e.g. round, taper-necked packagings or pail-shaped packagings. Wooden barrels and jerricans are not covered by this definition. " Jerrican" means a metal or plastics packaging of rectangular or polygonal cross-section with one or more orifices. " Box" means a packaging with complete rectangular or polygonal faces, made of metal, wood, plywood, reconstituted wood, fibreboard, plastics or other suitable material. Small holes for purposes of ease of handling or opening or to meet classification requirements, are permitted as long as they do not compromise the integrity of the packaging during carriage. 1.4.2 Table with IBC Codes (Intermediate Bulk Container) Mat rial Category Code Metal for solids, filled or discharged by gravity 11A for solids, filled or discharged under pressure 21A A. Steel for liquids 31A for solids, filled or discharged by gravity 11B for solids, filled or discharged under pressure 21B B. Aluminium for liquids 31B for solids, filled or discharged by gravity 11N for solids, filled or discharged under pressure 21N N. Other than steel or aluminium for liquids 31N Flexible woven plastics without coating or liner 13H1 woven plastics, coated 13H2 woven plastics with liner 13H3 woven plastics, coated and with liner 13H4 H. Plastics plastics film 13H5 without coating or liner 13L1 coated 13L2 with liner 13L3 L. Textile coated and with liner 13L4 multiwall 13M1 M. Paper multiwall, water resistant 13M2 for solids, filled or discharged by gravity, fitted with structural equipment 11H1 for solids, filled or discharged by gravity, freestanding 11H2 for solids, filled or discharged under pressure, fitted with structural equipment 21H1 for solids, filled or discharged under pressure, freestanding 21H2 for liquids, fitted with structural equipment 31H1 H. Rigid plastics for liquids, freestanding 31H2 Composite for solids, filled or discharged by gravity, with rigid plastics inner receptacle 11HZ1 for solids, filled or discharged by gravity, with flexible plastics inner receptacle 11HZ2 for solids, filled or discharged under pressure, with rigid plastics inner receptacle 21HZ1 for solids, filled or discharged under pressure, with flexible plastics inner receptacle 21HZ2 for liquids, with rigid plastics inner receptacle 31HZ1 HZ. Composite with plastics inner receptacle a for liquids, with flexible plastics inner receptacle 31HZ2

International Transport Regulations 24 Fibreboard G. Fibreboard for solids, filled or discharged by gravity 11G Wooden C. Natural wood for solids, filled or discharged by gravity with inner liner 11C D. Plywood for solids, filled or discharged by gravity, with inner liner 11D F. Reconstituted wood for solids, filled or discharged by gravity, with inner liner 11F a) The code shall be completed by replacing the letter Z by a capital letter to indicate the nature of the material used for the outer casing

International Transport Regulations 25 1.5 Marking and Labelling Marking The UN number preceded by the letters "UN" shall be clearly and durably marked on each package. Dimension of the mark: – The UN number and the letters "UN" shall be at least 12 mm high – For packages of 30 litres capacity or less or of 30 kg maximum net mass, they shall be at least 6 mm in height and except for packages of 5 litres or 5 kg or less when they shall be of an appropriate size. Unpackaged article: • the marking shall be displayed on the article, on its cradle or on its handling, storage or launching device. Marking shall be readily visible and legible and shall be able to withstand open weather exposure without a substantial reduction in effectiveness; IMDG Code requires test of at least three months' immersion in the sea. Lead-acid Batteries UN 2794, BATTERIES, WET, FILLED WITH ACID UN 2800, BATTERIES, WET, NON SPILLABLE UN 2796, BATTERY FLUID, ACID Nickel-Cadmium Batteries UN 2795, BATTERIES, WET, FILLED WITH ALKALI UN 2800, BATTERIES, WET, NON SPILLABLE UN 2797, BATTERY FLUID, ALKALI Nickel-Metal Hydride Batteries UN 3496, BATTERIES, NICKEL-METAL HYDRIDE Sodium-Nickel Chloride Batteries UN 3292, BATTERIES, CONTAINING SODIUM or UN 3292, CELLS, CONTAINING SODIUM Labelling Labels shall be in the form of a square set at an angle of 45° (diamond-shaped) with minimum dimensions of 100 mm by 100 mm, except in the case of packages of such dimensions that they can only bear smaller labels. They shall have a line 5 mm inside the edge and running parallel with it. Labels shall be readily visible and legible and shall be able to withstand open weather exposure without a substantial reduction in effectiveness; IMDG Code requires test of at least three months' immersion in the sea. Overpack The lettering of the “OVERPACK” mark shall be at least 12 mm high. The mark shall be in an official language of the country of origin and also, if that language is not English, French or German, in English, French or German, unless agreements, if any, concluded between the countries concerned in the transport operation provide otherwise; The package shall be labelled and marked with the UN number for each item of dangerous goods contained in the overpack. Each applicable mark or label only needs to be applied once.

International Transport Regulations 26 Marks and labels used in this manual: Handling Labels for IATA Minimum dimensions 120 x 110 mm

International Transport Regulations 27 1.6 Documentation Any carriage of dangerous goods governed shall be accompanied by the documentation prescribed in this chapter . Dangerous goods description is needed in the following sequence: UN n. / Proper shipping name / the label model (class)/ Packing Group (example: UN 2796, BATTERY FLUID , ACID, 8, II) Other information needed are: – the number and a description of the packages – the total quantity of each item of dangerous goods – the name and address of the consignor; – the name and address of the consignee(s). Specific documents are required by the different transport modes, which are described below, highlighting their own specificities that must be completed by the consignor. On the following pages are then shown examples of transport documents compiled Road Transportation – ADR Additional information required: • Tunnel restriction code Maritime Transportation – IMDG Code Additional information required: • Emergency response information, use in emergency response to accidents and incidents involving dangerous goods in transport. Air Transportation – IATA DGR Additional information required: • Limitation prescribed for passenger • Radioactive material

International Transport Regulations 28 Road Transportation – ADR No standard form is required for ADR transport document, this layout is an example. Consignor fills the parts in yellow of the document.

International Transport Regulations 29 Maritime Transportation – IMDG Code The layout of this form is not mandatory, but the information required are mandatory,Consignor fills the parts in yellow of the document. Note: Do not fill the Box n. 8

International Transport Regulations 30 Air Transportation – IATA DGR Consignor fills the parts in yellow of the document; In the bottom-right corner, the title of the person signing the declaration and the place of declaration is now optional and may be left blank.

International Transport Regulations 31 1.7 Special Provisions Battery Type Lead-acid NiCd Non spillable NiMH Na/NiCl Cells Na/NiCl Batteries Battery Fluid, acid Battery Fluid, alkali UN No. UN 2794 UN 2795 UN 2800 UN 3496 UN 3292 UN 3292 UN 2796 UN 2797 not subject to ADR 238 239 239 295 295 295 295 295 ADR 598 598 598 - - 29 117 238 239 239 295 295 IMDG 9 N 6 o 3 t restricted A48 A51 A51 A67 A94 A94 A164 A164 A164 A183 A183 A183 A183 A802 A802 IATA A199 Due to copyright restriction, on the ADR, IMDG and IATA regulations, this manual cannot contain the text of the special provisions applicable to the different transport modes, however, as a user, you can consult ADR at the following website: https://unece.org/transport/standards/transport/dangerous-goods/adr-2023-agreementconcerning-international-carriage - Chapter 3.3.1

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International Transport Regulations 33 1.8 Packing instructions Battery Type Lead-acid NiCd Non spillable NiMH Na/NiCl Battery Fluid, acid Battery Fluid, alkali UN No. UN 2794 UN 2795 UN 2800 UN 3496 UN 3292 UN 2796 UN 2797 not subject to ADR P001 P001 P003 PP16 P801 P801 P801 P801a P801a P801a P408 ADR IBC02 IBC02 P001 P001 P003 PP16 P801 P801 P408 IBC02 B20 IBC02 IMDG IBC08 see SP 963 Not restricted 492 Y840 Y840 851 851 855 855 870 870 IATA 872 Due to copyright restriction, on the ADR, IMDG and IATA regulations, this manual cannot contain the text of the packing instructions applicable to the different transport modes, however, as a user, you can consult ADR at the following website: https://unece.org/transport/standards/transport/dangerous-goods/adr-2023-agreement- concerning-international-carriage - Chapter 4.1.4

International Transport Regulations 34

International Transport Regulations 35 1.9 Transport Mode specific requirements 1.9.1 ADR - Exemption for quantity carried per transport unit Note: this exemption does not apply to IMDG Code and IATA DRG. This exemption is granted to loads not exceeding the amount specified in section 1.1.3.6 of the ADR. For transport of: not more than 333 kg of: UN 3292 Cells and Batteries containing sodium UN 2796 Battery Fluid, acid; UN 2797 Battery Fluid, alkali; and not more than 1000 kg of: UN 2794 Batteries, wet, filled with acid UN 2795 Batteries, wet, filled with alkali UN 2800 Batteries, wet, non spillable ! the following provisions do not apply: • identification document of the crew; • vocational training certificate (VTC) of the driver; • labelling and placarding of vehicles; • instructions in writing to the driver; • extinguishers for load compartments; There remain valid the following obligations: • marking and labelling packages; • prepare transport documents; • carry a fire extinguisher of at least 2 kg (powder); • prohibition on opening packages; • mixed loading prohibition; • portable lighting apparatus; • prohibition of smoking; • supervision of vehicles; • training for all staff, other than the drivers with the VTC, involved in the transport of dangerous goods by road 1.9.2 IMDG – Nickel-Metal Hydride batteries restrictions in maritime transportation According SP 963 nickel-metal hydride button cells or nickel-metal hydride cells or batteries packed with or contained in equipment are not subject to the provisions of IMDG Code. All other nickel-metal hydride cells or batteries shall be securely packed and protected from short circuit. They are not subject to other provisions of IMDG Code provided that they are loaded in a cargo transport unit in a total quantity of less than 100 kg gross mass. When loaded in a cargo transport unit in a total quantity of 100 kg gross mass or more, they are not subject to other provisions of IMDG Code except the required transport documents and to comply with Stowage, Handling and Segregation requirement.

International Transport Regulations 36 1.9.3 IATA - Restrictions of Portable Electronic Devices (PED) Containing Batteries Goods Acceptable without the Operator's Approval Electronic Devices (PED) (Including Medical Devices) Containing Batteries Battery-powered electronic device means the equipment or apparatus for which the batteries will provide electrical power for its operation. These devices (PED), which may include medical devices such as portable oxygen concentrators (POC) and consumer electronics such as cameras, mobile phones, laptops and tablets containing batteries when carried by passengers or crew for personal use, which should be carried in carry-on baggage. Batteries and heating elements must be isolated in portable electronic devices capable of generating extreme heat, by removal of the heating element, battery or other components. These provisions apply to dry batteries, nickel-metal hydride batteries, lithium batteries and wet, non-spillable batteries If devices are carried in checked baggage: (a) measures must be taken to protect the device from damage and to prevent unintentional activation; (b) the device must be completely switched off (not in sleep or hibernation mode). Spare batteries must be individually protected to prevent short circuits by placemen in the original retail packaging or by otherwise insulating terminals, e.g. by taping over exposed terminals or placing each battery in a separate plastic bag or protective pouch and carried in carry-on baggage only. Each person is limited to a maximum of 20 spare batteries; however, the operator may approve the carriage of more than 20 spare batteries. Additional requirements for non-spillable wet batteries: Each person is limited to a maximum of two spare batteries in carry-on baggage only, subject to the following conditions: (a) batteries must meet the requirements of Special Provision A67 and must not contain any free or unabsorbed liquid; (b) the voltage of each battery must not exceed 12 V and the Watt-hour rating must not exceed 100 Wh; (c) each spare battery must be protected from short circuit by insulation of the battery terminals.

International Transport Regulations 37 1.10 Training requirements Personnel shall be trained in the contents of dangerous goods provisions commensurate with their duties and responsibilities, before assuming responsibilities. Road and maritime regulations allow employees, for which required training has not yet been provided, to perform functions under the direct supervision of a trained person. Where the carriage of dangerous goods involves a multimodal transport operation, the personnel shall be aware of the requirements concerning other transport modes.

International Transport Regulations 38

International Transport Regulations 39 1.11 Batteries in vehicles Vehicles powered by batteries UN 3171 Battery-powered vehicles Class 9 This entry applies to vehicles powered by wet batteries, sodium batteries which are transported with these batteries installed. Vehicles are self-propelled apparatus designed to carry one or more persons or goods. Examples of such vehicles are electrically-powered cars, motorcycles, scooters, three- and four-wheeled vehicles or motorcycles, trucks, locomotives, bicycles (pedal cycles with an electric motor) and other vehicles of this type (e.g. self-balancing vehicles or vehicles not equipped with at least one seating position), wheel chairs, lawn tractors, self-propelled farming and construction equipment, boats and aircraft. In ADR and IMDG Code this includes also vehicles carried in a packaging. In this case some parts of the vehicle may be detached from its frame to fit into the packaging. ADR: Not subject to ADR Provisions of ADR do not apply to batteries installed in a vehicle, performing a transport operation and destined for its propulsion or for the operation of any of its equipment. Dangerous goods, such as batteries, airbags, fire extinguishers, compressed gas accumulators, safety devices and other integral components of the vehicle that are necessary for the operation of the vehicle or for the safety of its operator or passengers, shall be securely installed in the vehicle and are not otherwise subject to ADR. IMDG: Not subject to IMDG Code if special provision 961 is fulfilled SP 961 - Are not subject to IMDG Code vehicles solely powered by a wet or dry electric storage battery or a sodium battery, and the battery is protected from short circuit; Fully Regulated, if special provision 961 is not fulfilled. SP 962 - Vehicles not meeting the conditions of special provision 961 shall be assigned to class 9 and shall meet the following requirements: • vehicles not show signs of leakage from batteries, • installed batteries shall be protected from damage, short circuit, and accidental activation during transport The marking, labelling and placarding provisions of this Code shall not apply. IA F T u A l : ly Regulated, on Passenger and Cargo Aircraft; PI 952 - Battery-powered vehicles must meet the following requirements: • if spillable batteries are installed, and it is possible for the vehicle to be handled in such a way that batteries would not remain in their intended orientation, they must be removed and packed according to Packing Instruction 492 or 870, as applicable • if sodium batteries are installed they must not be offered for transport at a temperature such that liquid elemental sodium is present in the battery. All batteries must be installed and securely fastened in the battery holder of the vehicle and be protected in such a manner as to prevent damage and short circuits.

International Transport Regulations 40 Vehicles equipped with theft-protection devices, installed radio communications equipment or navigational system must have such devices, equipment or system disabled. Vehicles must be equiped with an effective means to preventing accidental activation. No quantity limits per package in Passenger and Cargo Aircraft Where vehicles could possibly be handled in other than an upright position, the vehicle must be secured in a strong, rigid outer packaging of the following type: Type Drums Jerricans Boxes Description Steel Aluminium Plywood Fibre Plastic Other metal Steel Aluminium Plastic Steel Aluminium Wood Plywood Reconstituted wood Fibreboard Plastic Other metal Hybrid electric vehicles powered by both an internal combustion engine and batteries (wet batteries, sodium batteries) transported with the battery(ies) installed, shall be assigned, in Class 9, to: • UN 3166, Vehicle, flammable gas powered or • UN 3166, Vehicle, flammable liquid powered, as appropriate. ➣ Not subject to ADR if any valves between the engine and fuel tank or the gas tank shall be closed during carriage ➣ Not subject to IMDG Code if special provision 961 is fulfilled Vehicles which contain an internal combustion engine shall be assigned, in Class 9, to: • UN 3166, Vehicle, flammable gas powered or • UN 3166, Vehicle, flammable liquid powered, as appropriate. ➣ Not subject to ADR if any valves between the engine and fuel tank or the gas tank shall be closed during carriage. ➣ Not subject to IMDG Code if special provision 961 is fulfilled. Vehicles powered by a fuel cell engine shall be assigned, in Class 9, to: • UN 3166, Vehicle, fuel cell, flammable gas powered or • UN 3166, Vehicle, fuel cell, flammable liquid powered, as appropriate. ➣ Not subject to ADR if any valves between the engine and fuel tank or the gas tank shall be closed during carriage . ➣ Not subject to IMDG Code if special provision 961 is fulfilled.

2. Shipping  Modes  Summary  Sheets

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Copyright  © www.batteriestransport.org 43 List of Summary Sheets Floated UN 2794 2.1.1.1.1 Automotive Non spillable UN 2800 2.1.1.1.2 2.1.1.1 Not regulated - 2.1.1.1.3 New 2.1.1 Floated UN 2794 2.1.1.2.1 Industrial Non spillable UN 2800 2.1.1.2.2 2.1.1.2 Not regulated - 2.1.1.2.3 Pb-acid 2.1 Fully regulated UN 2796 2.1.2.1 Electolyte 2.1.2 Limited Quantities UN 2796 2.1.2.2 used batteries UN 2794 2.1.3.1 Waste 2.1.3 Uncleaned empty containers UN 3509 2.1.3.2 Floated UN 2795 2.2.1.1 New Non spillable UN 2800 2.2.1.2 2.2.1 Not regulated - 2.2.1.3 Ni-Cd 2.2 Fully regulated UN 2797 2.2.2.1 Electolyte 2.2.2 Limited Quantities UN 2797 2.2.2.2 used batteries UN 2795 2.2.3.1 Waste 2.2.3 Uncleaned empty containers UN 3509 2.2.3.2 Ni-MH Maritime mode restrictions UN 3496 2.3 2.3 Cells UN 3292 2.4.1.1 New 2.4.1 Batteries UN 3292 2.4.1.2 Ni/NaCl 2.4 Cells UN 3292 2.4.2.1 Waste 2.4.2 Batteries UN 3292 2.4.2.2

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Copyright © www.batteriestransport.org 46 2.1.1.1.1 LEAD ACID BATTERIES – AUTOMOTIVE – FLOATED (free acid) UN 2794 Applies to: Lead-acid automotive batteries – SLI batteries (Starting, lighting, ignition) UN No., Proper Shipping Name UN 2794, BATTERIES, WET, FILLED WITH ACID Class 8 Packing Group not assigned Hazard Label • Labels must be in the form of a square set at an angle of 45° (diamond-shaped) with minimum dimensions of 100 mm by 100 mm; except for air transport mode, labels dimensions may be reduced in the case of packages of such dimensions that they can only bear smaller labels. • They must have a line 5 mm inside the edge and running parallel with it. Specific Requirements • Batteries must be protected against short circuit IATA Transport mode ADR IMDG Passenger Aircraft Cargo Exceptions Not subject to the requirements of ADR if comply with SP 598, when batteries are: • they are secured in such a way that they cannot slip, fall or be damaged; • they are provided with carrying devices, unless they are suitably stacked, e.g. on pallets; • there are no dangerous traces of alkalis or acids on the outside; • they are protected against short circuits Aircraft batteries up to a limit of 100 kg net weight per package may be transported. P801 P801 PI 870 Packing instructions Not approved packagings authorized: • Rigid outer packagings, wooden slatted crates or pallets; Additionally, the following conditions shall be met: • Battery stacks shall be in tiers separated by a layer of electrically nonconductive material; • Battery terminals shall not support the weight of other superimposed elements; • Batteries shall be packaged or secured to prevent inadvertent movement; • Batteries shall not leak under normal conditions of carriage or appropriate measures shall be taken to prevent the release of electrolyte from the package (e.g. individually packaging batteries or other equally effective methods); and • Batteries shall be protected against short circuits. Approved outer packagings meeting the Packing Group II performance standard, of the type: • Drums (1A2, 1B2, 1N2, 1H2, 1D, 1G); • Boxes (4A, 4B, 4N, 4C1, 4C2, 4D, 4F, 4G, 4H1, 4H2) • Jerricans (3A2, 3B2, 3H2). Additional requirements • metal packagings must be corrosion resistant or with protection against corrosion • must incorporate an acid/alkali-proof liner of sufficient strength and adequately sealed to pos • The batteries must be packed so that the fill openings and vents, if any, are upward; they are incapable of short- circuiting and they are securely cushioned in the packagings. itively preclude leakage in the event of spillage The upright position of the package must be indicated on it by the “Package Orientation” labels as shown in 7.2.4.4. Batteries in equipment • If batteries are shipped as an integral component of assembled equipment, they must be securely installed and fastened in an upright position and protected against contact with other articles so as to prevent short circuits. • Batteries must be removed and packed according to this packing instruction if the assembled equipment is likely to be carried in other than an upright position. Weight limit No limit No limit 30 kg Net 400 kg Net Tunnel code (E) - - - Transport cat. 3 - - - Exemptions chapter 1.1.3.6 limit ≤ 1000 kg Net - - - UN 2794 BATTERIES, WET, FILLED WITH ACID Full Name ad Address of the shipper and the consignee Net weight (kg) The words “THIS SIDE UP” or “THIS END UP” may also be displayed on the top of the package. Minimum dimensions: 74x105 mm Marking and Labelling of Packages when restricted UN 2974 UN 2794, BATTERIES, WET, FILLED WITH ACID Minimum dimensions 120×110 mm Overpack OVERPACK + same labels as above OVERPACK + same labels as above OVERPACK + same labels as above Documents Transport document MDGF Shipper’s Declaration

Copyright © www.batteriestransport.org 47 2.1.1.1.1 LEAD ACID BATTERIES – AUTOMOTIVE – FLOATED (free acid) UN 2794 ADR Not restricted Acid-proof liner IATA IMDG Securely cushioned

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