The Impact on Lithium Battery Transport by PHMSA Not Issuing HM-215N, The International Harmonization Final Rule

摘要

Clearly there are some problematic disharmonies if HM-215N is not issued. These include: 1.Continued requirement to subject large batteries, such as automotive batteries, to unnecessarily extreme shock tests; 2.Require different class 9 labels depending on whether the shipment involved ICAO/IMDG Code shipment or solely an HMR shipment if HM-215N is delayed beyond December 2018; and 3.Continued requirement for a document in the case of small batteries.