Given ongoing global
decarbonisation initiatives, there has been a resulting increase in the use of electric vehicles (EVs), electric scooters and bikes and electronic equipment and consumer goods generally. It has been predicted that the market for EVs will grow by 30% between 2020 and 2030. Therefore, the risk of such fires becoming more frequent during the carriage and transportation of Li-ion batteries or goods powered by them is a real one unless it is addressed head on. Stakeholders within the supply chain – including shipowners, carriers, freight forwarders, terminal and port operators, insurers and manufacturers – have been working together to manage the risks and reduce future exposure. Regulators are also considering whether existing regulations are inadequate and need to be revised.
In this article, we consider some issues arising and recent industry response.
Thermal runway
In simple terms, where a battery cell is damaged or faulty and overheats, it can result in a chemical reaction which itself generates more heat and the cell may gradually become so hot as a result of this chain reaction that toxic gases are produced. This can result in the battery becoming damaged, exploding, melting or catching fire. Such fires have incredibly high temperatures, can be self-perpetuating and very hard to extinguish.
CINS Network Guidelines In March 2023, the Cargo Incident Notification System (CINS) and Network, in conjunction with other industry stakeholders, produced the ‘Lithium-ion batteries in containers guidelines’.
The Guidelines state that the common causes of fires and explosions involving Li-ion batteries have been due to internal manufacturing defects, physical damage or substandard quality and internal electrical failure (overcharge, over-discharge or short circuit). Other fires have been related to packaging failures and mis-declaration of cargo or non-declaration of Li-ion batteries.
It is recognised that Li-ion battery technology is evolving rapidly and, therefore, risk control procedures for the safe transportation of Li-ion
Introducing transparency related to factory audit and supply chain know your customer procedures.
Further CINS guidelines are expected in due course, dealing with compliance, risk assessment and emergency response, as well as training and awareness.
It is worth noting that Maersk, one of the world’s largest container shipping companies, has issued a best practice for transporting EVs. It has also seized the market opportunity of developing specialised Li-ion battery and EV storage warehouses to mitigate the risks involved with storage. The storage facilities have advanced thermal monitoring systems that track battery temperatures, detect abnormalities and ultimately prevent fires from breaking out.
The Regulations
The relevant regulations are the IMO’s International Maritime Dangerous Goods Code (IMDG) for transport by sea, International Air Transport Association (IATA) for transport by air and the Agreement for the Carriage of Dangerous Goods by Road (ADR) for transport by road. All three sets of regulations are based on the UN Model Regulations on the Transport of Dangerous Goods, adapted where appropriate for specific circumstances
batteries and related goods may need to develop and evolve over time. However, the Guidelines recommend that the supply chain should improve its incident record relating to the transport of Li-ion batteries. Manufacturers and supply chain stakeholders are also advised to implement a number of measures, including:
Developing performance-based standards for Li-ion batteries;
Developing ventilation and cooling or extinguishing systems to manage thermal runway;
Updating industry standards, transport regulations and codes to address thermal runway risks;
Developing education, training and emergency response procedures;
Introducing Li-ion battery cargo screening, inspections and vanning surveys; and
for each mode. Different categories of batteries and battery-powered vehicles or equipment will have their own specific UN number. For rail transport, there is the International Carriage of Dangerous Goods by Rail (RID).
The regulations cover requirements for the construction and testing of batteries, classification and declaration of shipments, packaging and stowage.
Furthermore, the International Code for the Safe Carriage of Packaged Hazardous Articles (ICHCA) provides guidelines for safely transporting dangerous goods, including Li-ion batteries, by sea.
Batteries and devices that contain batteries are classified as dangerous goods and have to comply with specific packaging and shipping regulations. All Li-ion batteries, equipment powered by Li-ion batteries and Li-ion battery-powered vehicles are ‘Class 9’ under the UN Model Regulations and IMDG Code, which covers miscellaneous dangerous substances and articles. This is the least hazardous ranking and means they can be stowed above and below deck and with other dangerous goods.
Nonetheless, as dangerous goods, they must be declared and shipped as such under the applicable UN number. Additionally, the vessel will have a Document of Compliance (DOC) for dangerous cargo, which indicates where the batteries can be safely stowed on board. Furthermore, all batteries must be tested and must meet the specified criteria.
However, there are Special Provisions (SPs) complementing the UN classification. Smaller lithium batteries are considered to be less hazardous, even though they continue to be dangerous goods. Under SP 188, if they satisfy certain requirements, they can be transported under specific conditions and will not have to comply with other ADR/IMDG Code provisions, for example the carrier will not have to be specifically notified of the container’s contents.
In 2021, the UK Maritime and Coastguard Agency (MCA) published a marine guidance note (MGN 653(M)) on ‘Electric Vehicles onboard Passenger RoRo Ferries’. This notes
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