Do Lithium Batteries Require a Safety Data Sheet?

Rechargeable lithium-ion batteries are used to power consumer products like cell phones, laptops, power tools, hoverboards and e-cigarettes. Although generally safe and unlikely to fail, the risk of overheating, fires, and explosions increases when lithium batteries have defects or when the batteries are damaged. Improper use, storage and charging also cause lithium batteries to fail.  

Many products containing lithium batteries are regulated by consumer safety laws but do not come with a safety data sheet (SDS) when you purchase the product at a local store. Battery manufacturers may provide an SDS as a measure of product stewardship but it’s typically not necessary for employers to maintain the SDS as the batteries are considered to be a “manufactured article”. Manufactured articles refer to any item that meets the following conditions: 

1. It is formed into a shape or design during the manufacturing process. 

2. Its intended use depends on that design. 

3. It will not release or cause an individual to be exposed to a hazardous product under normal conditions. 

4. It will not release or cause an individual to be exposed to hazardous products when being installed.

In theory, the end user of a manufactured article will not come in contact with the hazardous material under normal conditions of use and foreseeable emergencies.  

Are Batteries Considered Manufactured Articles?

Lead-acid batteries are not considered manufactured articles because they have access ports for the end user to manage the fluid level and have a significant potential to leak, spill, break, and emit hydrogen gas, which could result in a fire or explosion upon ignition.  

Similarly, lithium-ion batteries (or lithium battery-powered devices), although sealed, have a significant potential to leak, spill, or break during normal conditions of use and foreseeable emergencies and expose employees to chemicals with health (e.g., lithium cobalt, graphite) and/or physical (e.g., bums, fire) hazards, and therefore, cannot be considered a manufactured article.

The Classification of Lithium Batteries

Lithium batteries fall into two broad classifications: lithium metal batteries and lithium-ion batteries:

• Lithium metal batteries are generally non-rechargeable and contain metallic lithium.

• Lithium-ion batteries contain lithium which is only present in an ionic form in the electrolyte and are rechargeable.

OSHA Hazard Communication Plan for Lithium Battery Fire Safety

A lithium battery can have one or more lithium cells that are electrically connected. The heat released during cell failure can damage nearby cells, releasing more heat in a chain reaction known as a thermal runaway. The high energy density of lithium batteries makes them more susceptible to these reactions. 

Due to the prevalence of lithium battery fires, OSHA issued a safety alert with guidelines on the training and safe use of lithium batteries that should be included in a hazard communication plan:

• Lithium batteries should adhere to national safety standards (NRTL) where applicable. 

• Follow manufacturers’ instructions for storage, use, charging and maintenance.  

• Replacement batteries and chargers should match and be from the original manufacturer or authorized reseller. 

• Remove lithium batteries from their charger when fully charged.  

• Store devices and batteries in a fire-resistant container and in a cool, dry location.  

• Inspect the batteries for damage before use. If found do not use and place away from flammable materials.  

• Ensure workers remove a device from clothing if it feels hot or shows signs of damage.  

• Follow local, state, and federal regulations on proper disposal. Find a local battery recycling center.  

• Follow manufacturer guidelines when extinguishing small battery fires.

Lithium Batteries and Transportation Regulations

Lithium batteries are considered dangerous goods that pose a safety risk if not shipped in accordance with transport regulations. Lithium batteries present both chemical and electrical hazards. Lithium batteries pose hazards during transport including: 

1. Short circuits, which can lead to fires; and/or 

2. Leaks of corrosive liquid or other material that can injure people or harm the environment. 

Lithium batteries can overheat and ignite under certain conditions and once ignited, can be difficult to extinguish. There is a possibility that a lithium battery is susceptible to thermal runaway, a chain reaction leading to a violent release of its stored energy.

Who is Responsible for Classifying Lithium Batteries as a Dangerous Good?

The consignor/shipper is responsible for classifying dangerous goods such as lithium batteries. There are different UN numbers for lithium batteries and rules for shipping based on the type of battery and method of shipping (air, marine, or road). Research the shipping regulations in your area for specific guidelines on shipping rules and papers. 

IATA has developed guidance for shippers, freight forwarders, ground handlers, airlines, and passengers for lithium batteries during air transport. Transport Canada and the U.S Department of Transportation also have guidelines listed for lithium transport.

Do You Work with Lithium Batteries? Make Sure You Have a Safety Plan in Place.

If your business commonly works with lithium batteries or other hazardous goods consider Chemscape’s safety data sheet management software to help establish strong SDS management within your workplace.