When we were cute little smart-aleck boys barely old enough for school, we used to enjoy saying “I ain’t gonna say ain’t no more, cuz ain’t ain’t a word in the dictionary. Ain’t that great?”
The word ain’t may or may not actually be in the dictionary, but I do know what it means. It’s plain American, my native tongue. Of course, I’m not always so knowledgeable. Once upon a time I thought I knew what a battery is. You know, one of those energy storage thingies that we use to power our portable electronic devices. Or, as in the case of a wireless household security system, a non-portable electronic device that detects when a door or window has been opened. I’ve purchased these “battery” things at a local store, and the packaging says “batteries”. But then, I needed to offer some for transport.
The UN Manual of Tests and Criteria says a cell is a single encased unit with voltage differential. IATA says a battery is two or more cells electrically connected together. Thus, transport regulations say a single cell battery is not really a battery. And apparently the distinction is important. Many DG transport packing instructions (PI), packaging authorizations, or special provisions (SP) list different maxima for cells vs. batteries. Okay. If that’s the way the regs say it’s gotta be, then that’s the way it’s gonna be.
It took some doing, but I found out that some of these small lithium metal thingies powering my camera, or my laser pointer, or powering the open/close detector on my home’s windows have only one cell. Thus, despite the consumer packaging, they are cells rather than batteries, and must be classified, packaged, and transported according to the DG cell limits, not the battery limits. At least I think so. I’m having some trouble finding the lithium metal cell Proper Shipping Names (PSNs) in the ‘blue pages’ (DG Lists, HazMat Tables). If I can’t find an appropriate PSN, then I can’t know which PIs, SPs, or authorizations to read. I know there’s a cell vs. battery distinction. The definitions quoted earlier and the lithium “battery” PIs and SPs told me there’s a distinction. But I still can’t find a “cell” PSN. Could it possibly be that the regulations treat cells as batteries for classification purposes, but insist we know the difference for packaging and communication exception purposes? So, maybe, from an air transport perspective I could say that in the blue pages ‘cell = battery’, but in the yellow pages ‘cell ≠ battery’? Really?
Seriously, are the regulations telling me that it’s important to distinguish between a cell and a battery, except that we’re going to call them all batteries, regardless? Whew. I ain’t finding a whole lot of sense in that. But maybe it’s just me. After all, I’m having trouble with “function specific” as well.
I’ve been in training classes with a variety of interesting people from a lot of different companies. We learned the regulations regarding the sequence of information on transport documents, but we didn’t learn any of the specifics about how any of the companies generate the documents. Some companies generate documents manually, using that ancient piece of equipment, the typewriter. Others use Word or Excel to align the pieces of information properly, and then inkjet or laser print them onto blank forms. And yet some other companies have sophisticated DG printing programs that do most of the work, but we still weren’t instructed on whether to push F8, or CTRL + P, or shift + F11 to actually commence printing. So, was our training general, specific, or somewhere in between?
Packaging regulations were covered in a similar fashion. We discussed boxes and drums and totes (IBCs). But the new compliance manager for Company X didn’t get trained on whether her company’s DG product PDK gets packaging into jerricans or drums. Nor did she get trained on whether, because of gross weight or density or PG, Company X stocks DG packaging that’s good for some HazMat products but not for others. When we learned that for some IBCs we get to choose whether to label or placard the package, Corporation J’s EHS manager didn’t get instructed on whether his bulk products division chooses labels, or placards incorporating identification numbers, or placards adjacent to identification number markings. Yet, certificates, and presumably certifications, issued for successful completion of the course conducted in the hotel stated “function specific” requirements had been met. Language, again. Yes, specific regulations affecting certain functions were training topics. Yet, how to specifically perform those functions at a specific facility wasn’t covered. Function specific, or not?
I guess a cell isn’t a battery, except when it is a battery. And that function specific training is sometimes specific to the regulations, other times specific to how certain tasks are performed, and sometimes just general about the regulations. I think that’s the way it is, but I’m not real sure. What am I sure about?
I’m sure that despite my decades of experience and study, I ain’t got as good a grasp of what the wording used in the regulations means as I wish I had. How about you? Ain’t you on the same page as me?
Written 3/27/2015 for HCB Magazine