44
SPOT THE SIGNS BATTERIES • THE US COAST GUARD WARNS OF THE POTENTIALLY CATASTROPHIC IMPACT OF A LITHIUM BATTERY FIRE, FOLLOWING A RECENT INCIDENT IN A CONTAINER BOUND FOR LOADING THE US COAST Guard (USCG) has issued a Safety Alert (01-22) that seeks to raise awareness of the risks involved in the carriage of lithium batteries in containers. The alert follows an investigation by the Department of Transportation (DOT) and its Pipeline and Hazardous Materials Safety Administration (PHMSA) of a fire in a container heading to be loaded onto a ship for transport to China. The container had been loaded in Raleigh, North Carolina and was being transported by road when it caught fire on 19 August 2021. The bill of lading showed the cargo as containing ‘computer parts’ but these were in fact lithium batteries. The fire consumed the cargo and significantly damaged the container itself – the fire was fierce enough to burn through the steel. The lack of accurate information on the load made the firefighting response difficult; USCG also notes that, had the cargo made it onto the ship and caught fire while at sea, the results could have been catastrophic for the vessel and its crew. DOT and PHMSA determined that the shipper failed to properly placard, label, mark and package the lithium batteries (UN 3480 and 3481, Class 9); it was identified that the cause of the fire was to do with residual charge that led to the heating in one or some of the batteries and eventually a thermal runaway. KNOW THE RISKS USCG is aiming to raise awareness of the hazards of lithium batteries in ocean transport
A CONTAINER FULL OF BATTERIES HAS THE POTENTIAL TO CAUSE A GREAT DEAL OF DAMAGE
HCB MONTHLY APRIL 2022
and, in particular, the risks involved in the mis-declaration of such cargoes. It has asked stakeholders to disseminate the safety alert to all maritime personnel. It also highlights special provisions 376 and 377 in the International Maritime Dangerous Goods (IMDG) Code, which require additional marking requirements for lithium batteries that are damaged or defective, or being transported for the purpose of disposal or recycling. Stakeholders should ensure that damaged or defective batteries are packaged in accordance with packing instructions P911 or LP906 and that batteries for disposal or recycling meet P908 or LP904. All those
provisions require cells and batteries to be protected against short circuit and some provide additional direction on isolating each cell/battery or place limits on the volume of batteries permitted in each package. USCG also points to PHMSA’s Lithium Battery Guide and guidance from the US Environmental Protection Agency (EPA) on used lithium ion batteries. For those wondering how much non-compliance could cost them, Appendix A to Subpart D of 49 CFR 107 contains guidance on civil penalties and other enforcement actions. The Safety Alert was timely as USCG has since investigated a similar event at the port of Los Angeles-Long Beach, when a fire broke out on 4 March in a container at San Pedro Bay, while waiting to be loaded for export to China. In this case the cargo was declared as “synthetic resins” but again was actually used lithium ion batteries. USCG and PHMSA worked with other agencies to identify and inspect all containers at the port from the same shipper and USCG has placed a hold on all of the shipper’s outbound boxes. The Safety Alert can be found online at www. dco.uscg.mil/Portals/9/DCO%20Documents/5p/ CG-5PC/INV/Alerts/USCGSA_0122.pdf.
