Transporting Prototype Batteries Before UN 38.3 Testing: (SP310)

Before a new lithium cell or battery design has completed UN 38.3 testing, it may still need to be transported to a laboratory for testing and qualification. ADR Special Provision 310 (SP 310) provides a route for eligible pre-production prototypes and small production runs to be transported for testing before the normal UN 38.3 testing requirement has been satisfied.

What Is ADR Special Provision 310?

ADR Special Provision 310 provides a transport route for eligible pre-production prototype cells and batteries, and qualifying small production runs, that need to be transported for testing before the applicable testing requirements have been completed.

Special Provision 310 applies to:

  • Cells or batteries from production runs of not more than 100 cells or batteries.

  • Pre-production prototypes of cells or batteries when they are being carried for testing.

For these cells and batteries, SP 310 provides specified exceptions from the requirements of ADR 2.2.9.1.7.1, including the requirement relating to successful completion of the tests in the UN Manual of Tests and Criteria, Part III, subsection 38.3.

This means that an eligible prototype does not need to have already completed UN 38.3 testing simply to be transported to a laboratory for that testing. Instead, it must meet the applicable requirements of SP 310, including the use of P910 or LP905 packaging, as applicable.

Packaging Prototype Batteries Under SP 310

Prototype cells and batteries transported under SP 310 must be packaged in accordance with P910 or LP905, as applicable.

ADR requires the applicable cells and batteries to be packaged in accordance with:

P910 Packaging Requirements:

P910 provides a packaging route for applicable prototype and small-production-run cells and batteries. It covers the relevant lithium battery entries UN 3090, UN 3091, UN 3480 and UN 3481.

Individual Packaging

Each cell or battery must be individually packed in an inner packaging and then placed inside an approved outer packaging.

The outer packaging may be a specified:

  • Drum

  • Box

  • Jerrican

    The selected packaging must conform to the Packing Group II performance level.

    Thermal Protection

    Each inner packaging must be completely surrounded by sufficient non-combustible and electrically non-conductive thermal insulation material.

    This insulation is intended to protect the package against dangerous heat development.

    Batteries Over 30 kg

    Where an individual cell or battery has a net mass greater than 30 kg, only one cell or battery may be placed in each outer packaging.

    This does not mean that batteries above 30 kg must automatically use LP905. The 30 kg provision is a restriction within P910 rather than a fixed crossover point between P910 and LP905.

LP905 Large Packaging Requirements

LP905 provides the corresponding large-packaging route for eligible prototype and small-production-run batteries transported under SP 310. It can be used for a single battery or a single item of equipment containing cells or batteries.

What Large Packaging Can Be Used?

LP905 permits rigid large packagings meeting the Packing Group II performance level.

Permitted materials and packaging codes include:

  • Steel – 50A

  • Aluminium – 50B

  • Metal other than steel or aluminium – 50N

  • Rigid plastic – 50H

  • Natural wood – 50C

  • Plywood – 50D

  • Reconstituted wood – 50F

  • Rigid fibreboard – 50G

Individual Battery Packaging

A single battery must be placed inside an inner packaging, which is then placed within the rigid large outer packaging.

The inner packaging must be completely surrounded by sufficient non-combustible and electrically non-conductive thermal insulation material to protect against dangerous heat development.

Overlapping Packaging Requirements for P910 and LP905

Thermal Protection

For individually packaged cells or batteries, the inner packaging must be surrounded by sufficient non-combustible and electrically non-conductive thermal insulation material to protect against dangerous heat development.

Protection From Movement and Damage

Appropriate measures must be taken to:

  • Minimise the effects of vibration and shock.

  • Prevent movement of the cell, battery or equipment within the packaging.

  • Prevent movement that could cause damage or create a dangerous condition during transport.

Where cushioning is used to provide this protection, the material must be non-combustible and electrically non-conductive.

The non-combustibility of the applicable thermal insulation and cushioning materials must be assessed against a standard recognised in the country where the packaging is designed or manufactured.

Packaging Performance and Mass

The applicable packaging must meet the required Packing Group II performance level.

Where cells or batteries of different sizes, shapes or masses are packed in an applicable tested packaging design, the total gross mass of the completed package must not exceed the gross mass for which the packaging design type was tested.

Batteries Contained in Equipment

Both packaging routes provide requirements for batteries contained in equipment. Appropriate measures must be taken to protect the equipment against vibration, shock and movement that could cause damage or create a dangerous condition during transport.

The specific packaging configuration and additional requirements depend on whether P910 or LP905 is being used.

P910 or LP905: Which Applies?

Both P910 and LP905 provide packaging routes for eligible prototype and small-production-run batteries transported under SP 310:

  • P910 uses specified conventional outer packagings, including drums, boxes and jerricans.

  • LP905 uses specified rigid large packagings and is limited to a single battery or a single item of equipment containing cells or batteries.

The applicable packaging route must be selected according to the battery and proposed packaging configuration.

A battery weighing more than 30 kg does not automatically have to use LP905. Under P910, the 30 kg provision limits the package to one cell or battery rather than creating a mandatory threshold for switching to LP905.

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