Key takeaways
Small battery exemption
Shipping industry seeks reform to close loophole causing increased fire risk to vessels.
Significant fire risk
Consolidated battery loads can create significant fire risks classified as general cargo.
Visibility improves safety
Relevant disclosure of cargo supports implementation of appropriate risk mitigation measures.
Following a number of high-profile vessel fires involving lithium-ion battery powered electric vehicles (EVs) in recent years, industry attention is increasingly turning to a significant gap in the regulatory framework in relation to the transportation of the types of lithium-ion batteries used in consumer electronics, which have been shown to present a comparable fire risk to EVs.
Under Special Provision 188 (SP188) of the International Maritime Dangerous Goods (IMDG) Code, low wattage lithium-ion batteries, such as those contained in consumer electronics like laptops, mobile phones, and smartwatches, may be shipped without a dangerous goods declaration provided they fall below specified energy thresholds.
Whilst individual packages are subject to hazard marking requirements, there is currently no limit on the number of qualifying low wattage battery units that may be consolidated within a single container. As a result, containers carrying significant concentrations of lithium-ion batteries may be transported and stowed as general cargo.
This lack of visibility has significant safety implications. Without an appreciation of the nature and scale of the battery cargo on board, some carriers may fail to make appropriate stowage decisions or implement appropriate risk mitigation measures.
Unlike conventional cargo fires, lithium-ion battery fires can involve thermal runaway and re-ignition, meaning that traditional smothering systems such as CO₂ or foam are largely ineffective. Instead, firefighting efforts must focus on prolonged cooling and containment, including, where possible, the submersion of affected cargo in water or the use of hydro-pendant misting systems.
The SP188 exemption was introduced in the 1990s to reduce the compliance burden associated with shipping relatively small quantities of consumer electronics. However, this exemption was created in a markedly different commercial environment and is increasingly difficult to justify in light of the widespread adoption of battery powered consumer devices and the substantial growth in the volume of lithium-ion batteries transported worldwide.
The industry has taken some steps to address the risks associated with the maritime transport of EVs. IMDG Code Amendment 42-24 introduced a new classification, UN 3556 (Vehicle, Lithium-Ion Battery Powered), for EVs. This classification mandates hazard labelling and imposes a requirement for EVs to be transported with no more than 30% charge during transit.
International shipping organisations and interested member states are now calling on the IMO to close the regulatory blind spot created by the SP188 exemption as a matter of urgency. Proposals include imposing limits on the number of qualifying battery units that may be consolidated within a single container, with shipments exceeding those thresholds becoming subject to enhanced hazard notification, marking and declaration requirements.
More broadly, questions remain as to whether existing vessel firefighting infrastructure is adequately equipped to address the challenges posed by lithium-ion battery fires, particularly where large concentrations of batteries are carried on board.
Until more advanced detection, containment and suppression technologies are developed, battery related incidents will continue to represent a significant risk to vessels, cargo and crew. In the interim, measures aimed at improving transparency and reducing the likelihood of such fires should be welcomed.
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This article was co-authored by Associate, Cleo Lines.
