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Ensuring the Safe Transport of Battery Energy Storage Systems on Maritime Vessels
In recent months, Gard has received numerous inquiries about the safe transportation of battery energy storage systems (BESS) aboard ships. This article addresses some of the key risks, regulatory requirements, and recommendations for shipping such cargo.
Battery energy storage systems (BESS), often referred to as energy storage cabinets or megapacks, are integral to the clean energy transition, according to the International Energy Agency. These systems consist of multiple devices assembled into a single unit capable of storing significant amounts of energy. Among the various types of energy storage systems (ESS), BESS are the most prevalent, especially those utilizing pre-assembled lithium-ion battery modules. Due to their growing usage, a focus on lithium-ion battery-equipped BESS is crucial.
Declaration of BESS
Siddharth Mahajan, a Senior Loss Prevention Executive in Singapore, notes that lithium-ion BESS are classified as dangerous goods per the IMDG Code. The IMDG Code provides multiple descriptions and shipping names for lithium cells and batteries, depending on their chemical composition and whether they are stand-alone, integrated within equipment, or contained within vehicles or cargo transport units. This variety has led to some confusion regarding proper cargo declaration. BESS have been declared under:
- UN 3480 (Lithium-ion batteries)
- UN 3481 (Lithium-ion batteries contained in equipment or packed with equipment)
- UN 3536 (Lithium batteries installed in cargo transport units)
Carriers must be aware of the relevant special provisions (SP) of the IMDG Code. For example, SP 389, which pertains to the securing of batteries within the interior of cargo transport units, applies specifically to UN 3536. Various SPs relevant to UN 3480 and UN 3481 do not pertain to UN 3536. Proposed changes to UN 3536 are discussed further in the 'stowage and securing' section.
Fire and Explosion Risks
Lithium-ion batteries present significant fire and explosion hazards, a current topic of concern in the shipping industry. As a preventive measure, ship owners should inquire about the state of charge (SoC) of the BESS before accepting shipment, as it influences the probability of thermal runaway fire, growth, and peak heat release rate. Regulatory bodies like EMSA and AMSA recommend maintaining a minimum SoC during transportation to mitigate risks.
Despite most BESS incorporating inbuilt battery management and cooling systems, thermal runaway incidents can still occur. Most units are designed to vent from the top. If stowed in a hold, the resulting toxic vapors could accumulate, posing explosion risks. Effective venting can be challenging, and there is a need to avoid igniting vapor clouds. Containing the situation and consulting experts is advisable. Some units may feature safety systems allowing remote monitoring to preemptively address potential dangers. Crew members should be aware of vapor toxicity and take precautions to prevent gases from reaching inhabited areas.
Stowage and Securing
When transporting BESS on bulk carriers and general cargo vessels, the following factors should be considered:
- Securing Arrangements and Cargo Spaces: If the vessel lacks adequate securing arrangements, modifications may be necessary under expert supervision, requiring Administration approval.
- Structural Strength: The tank top and hatch covers' structural strength must be verified.
- Cargo Securing Manual (CSM): The CSM should be reviewed to ensure it covers the carriage of BESS, with any necessary amendments approved by the Administration.
- Approvals: Approval from the vessel’s Classification Society and Flag State may be required. Owners should engage these entities early to understand requirements and the approval process.
Recommendations
- Load cargo in accordance with IMO statutory requirements, the vessel’s CSM, CSS Code, and IMDG Code.
- Obtain necessary approvals from the vessel’s Classification Society and/or Flag State.
- Request charterers and shippers to provide detailed information on special handling instructions, state of charge, battery types, in-built safety features, and emergency response protocols.
- Adopt a risk-based approach for stowage location, considering draft amendments to the IMDG Code (42-24).
- Equip vessels with additional fire safety equipment for effective fire and explosion detection and response, and ensure crew are provided with specific training and emergency response guidance.
By adhering to these guidelines, ship owners can mitigate the risks associated with transporting BESS and ensure safe and compliant shipping practices.