Some, but not all, non-spillable lead acid batteries are classified as a dangerous good and hence their transport requirements are outlined in the “Australian Code for the Transportation of Dangerous Goods by Road & Rail” (ADGC). The following article will help you determine when they are considered to be a dangerous good and what the transport regulations are.
In Australia, the transport requirements for dangerous goods are set out in the “Australian Code for the Transportation of Dangerous Goods by Road & Rail” (ADGC). The National Transport Commission‘s (NTC) maintains and updates the code and a copy of the current edition can be found and downloaded for free at their webpage.
Spillable or flooded batteries have liquid electrolyte, such as those found in most car batteries, and are classified with the UN Dangerous Good Number, 2794 and Proper Shipping Name “BATTERIES, WET, FILLED WITH ACID, electric storage”. For a detailed summary of the transport regulations for spillable (wet) lead acid batteries.
Non-spillable lead acid batteries are often referred to valve regulated lead acid (VRLA) or sealed lead acid (SLA) batteries. And there are two main types of VRLA batteries, absorbent glass mat (AGM) and gel cell.
How do I determine if my battery is non-spillable?
The simplest method is to examine the labelling on the battery itself. You should find somewhere words to the effect “non-spillable” “seal lead acid battery” “seal valve regulated lead acid battery” “valve regulated” “AGM”. If you are still unsure consult the battery manufacture’s safety data sheet.
When is a non-spillable lead acid battery not a dangerous good?
So, when is a non-spillable battery not classified as a dangerous good? Firstly, batteries must pass a vibration and pressure test to be classified as a non-spillable battery. These requirements are laid out in the ADGC under the UN Special Provision 238. This provision includes an additional test to determine that there will be no free flow of the electrolyte at 55 degrees C, from a rupture or cracked battery case.
If the battery has passed this test, it is not classified as a dangerous good and hence its transportation is not covered by the provisions of the ADGC. The simplest way to determine if your battery has met this requirement is to refer to the manufacturer’s safety data sheet. Which should include a section titled “Transport Information”, where you will find if the battery has met the requirements of Provision 238 thereby exempting the batteries from the ADGC requirements for transport by road and rail.
Unfortunately, it has been our experience that not all safety data sheets contain this information. If you are unable to determine from the manufacturer whether the battery has passed this test and hence is exempt from the dangerous good transport provisions., our recommendation is that you treat the battery as a dangerous good.
Irrespective of whether the sealed lead acid battery is classified as a dangerous good or not, the batteries’ terminals, when packaged for transport, must be protected from short circuit.
If your non-spillable battery is a dangerous good, what are the transport requirements?
If it has been determined that your non-spillable battery is a dangerous good , then it will need to be transported as per the ADGC requirements.
Non-spillable batteries are classified under the ADGC with the UN Dangerous Good Number, UN2800 with the Proper Shipping Name “BATTERIES, WET, NON-SPILLABLE, electric storage”.
The ADGC Packing Instruction P003, specifies the packing requirements for transporting these batteries. Below is an excerpt of this packing instruction showing the requirements that are applicable to non-spillable batteries.
| P003 PACKING INSTRUCTION P003 |
| Dangerous goods must be placed in suitable outer packagings. The packagings must meet the provisions 4.1.1.1, 4.1.1.2, 4.1.1.4, 4.1.1.8 and 4.1.3 and be so designed that they meet the construction requirements of 6.1.4. Outer packagings constructed of suitable material, and of adequate strength and design in relation to the packaging capacity and its intended use, must be used. Where this packing instruction is used for the transport of articles or inner packagings of combination packagings the packaging must be designed and constructed to prevent inadvertent discharge of articles during normal conditions of transport. Special packing provisions: PP16 For UN 2800:(a) batteries must be protected from short circuit within the packagings |
Unless you are remarkably familiar with the ADGC the above packing instruction won’t make much sense. So, what does it mean? Batteries are defined as an article under the ADGC, so the requirement is essentially “the packaging must be designed and constructed to prevent inadvertent discharge of articles during normal conditions of transport”. Thus, the use of wood pallets & crates (defined as an overpack in the ADGC) and plastic bins would all be acceptable options.
What are the other ADGC requirements?
When transporting non-spillable batteries other ADGC requirements such as labelling, dangerous goods documentation, load restraint, emergency information and vehicle placarding, have to also be met. These are similar to the requirements for spillable or flooded batteries, classified as “BATTERIES, WET, FILLED WITH ACID, electric storage” UN Number 2794 under the ADGC.
You can find here a detailed summary of the transport requirements for spillable lead acid batteries. The Proper Shipping Name and UN Number should be substituted where appropriate.
What other regulations control the transport of non-spillable lead acid batteries?
Used or waste Lead acid batteries are classified as a hazardous and controlled waste in most States. Regulations governing the transport of hazardous waste have been enacted by each State or Territory. These controlled hazardous waste regulations do not distinguish between different types of lead acid batteries. In other words, all lead acid batteries are a controlled hazardous waste.
You can find the link to your state or territories hazardous waste regulations.
