Special Provision 238 (SP 238) provides an exemption for certain non-spillable batteries, including batteries assigned to UN2800 – BATTERIES, WET, NON-SPILLABLE.
When all requirements of SP 238 are met, qualifying batteries may not be subject to the other dangerous goods transport requirements.
What Is a Non-Spillable Battery?
Non-spillable batteries are commonly sealed lead-acid or similar batteries designed so the electrolyte will not flow from a ruptured or cracked case under specified conditions.
However, simply being described by a manufacturer as “sealed” or “non-spillable” does not automatically provide an exemption.
The battery must meet the applicable testing and transport requirements.
What Does SP 238 Require?
To qualify for the SP 238 exemption, the battery must meet specific requirements, including the prescribed vibration and pressure differential tests.
At the required test conditions, there must be no leakage of electrolyte.
The battery must also be protected against short circuits, and the applicable packaging and marking requirements must be met.
Are Non-Spillable Batteries Dangerous Goods?
UN2800 batteries are Class 8 dangerous goods, but batteries meeting all the requirements of SP 238 can receive significant relief from the normal dangerous goods transport requirements.
This is why it is important to obtain appropriate supporting information from the battery manufacturer rather than assuming a sealed battery is exempt.
What About Lithium Batteries?
SP 238 should not be confused with the exemptions available for lithium batteries.
Lithium-ion and lithium-metal batteries have their own transport requirements and special provisions, including SP 188 for certain smaller lithium batteries.
If your battery is listed as UN2800 or your SDS references SP 238, we can help determine the applicable packaging, documentation and transport requirements.