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In the past few months, Gard has received several queries on the safe carriage of battery energy storage systems (BESS) on ships. In this insight, we highlight some of the key risks, regulatory requirements, and recommendations for shipping such cargo.
According to the International Energy Agency, energy storage systems (ESS) will play a key role in the transition to clean energy. Sometimes referred to as "energy storage cabinets" or "megapacks", ESS consist of groups of devices that are assembled together as one unit and that can store large amounts of energy.
Battery energy storage systems (BESS) are the most common type of ESS where batteries are pre-assembled into several modules. BESS come in various sizes depending on their application and their usage is expected to rise considerably in coming years. Although different kinds of batteries can be used in BESS, lithium-ion batteries seem to be the most popular. Our focus in this article is therefore on energy storage systems equipped with lithium-ion batteries.
Declaration of BESSBESS with lithium-ion batteries is classed as a dangerous cargo, subject to the provisions of the IMDG Code. In the IMDG Code, there are multiple descriptions and shipping names for lithium cells and batteries, depending on their chemistry and whether they are stand-alone, within equipment, contained within vehicles or cargo transport units. This has caused some confusion among shippers about how to correctly declare this cargo. We have come across instances where a BESS is declared as either:
• UN 3480 (Lithium-ion batteries), or• UN 3481 (Lithium-ion batteries contained in equipment or lithium-ion batteries packed with equipment), or• UN 3536 (Lithium batteries installed in cargo transport unit).
Carriers should also be aware of the applicability of the different special provisions (SP) of the IMDG Code. SP 389 (which mentions the securing of batteries to the interior structure of the cargo transport unit) is applicable only to UN 3536. Similarly, a lot of other SPs which are applicable to UN 3480 and UN 3481 do not apply to UN 3536. There are some changes proposed to UN 3536. For more details on this, see below in the section ''stowage and securing''.
There have been instances on shore where BESS have had a thermal runaway incident and subsequent explosion, like the 2019 incident in Arizona. In an attempt to deal with such fires, the container doors have been opened to gain access, which has resulted in explosions and in some cases significant injuries. Some BESS with inbuilt detection systems will activate an auto-release firefighting agent. However, a challenge with such systems is how they can be connected to the ship''s system so that the crew will know which container is of concern.
A combination of measures may be required to contain or bring a lithium-ion battery fire under control. These include improved automatic fire detection alarm systems, CCTV and thermal imaging equipment for cargo spaces to enable earlier detection, appropriate and upgraded personal protective equipment (PPE), and provisions for the use of copious amounts of water.
Lithium-ion batteries may also continue to generate a lot of heat after the fire has been extinguished and are at risk of re-ignition. A decision to fight the fire manually should only be made when it is deemed safe for the crew. Owners are advised to assess the suitability of existing fire detection and firefighting equipment onboard their vessels for lithium-ion battery fires. Crew should also receive training in how to respond to lithium-ion battery fires.
• Stowage category changed from ''A'' (on deck or under deck) to ''D'' (on deck).• Stowage codes ''SW1'' (Protected from sources of heat) and ''SW2'' (Clear of living quarters) will be applicable to such shipments.
Tilting and vibrationsBESS units may also have a limitation on how much they can be tilted from the vertical during loading/unloading and transportation. The safety of its components may be compromised if the units are tilted beyond the limits. These limits will be defined by the manufacturer. If no information is supplied to the carrier at the time of shipment, the shipper should provide clarification on this. The vessel''s movement at sea should also be factored in when accepting cargo units where the tilting angle limitations are marginal.
Heavy vibrations and rough handling of the BESS units can cause damage to the batteries and various other associated fittings. If the crew notice that the cargo is not handled properly during loading or if it makes heavy contact with the cargo hold structure, further checks should be carried out before accepting a BESS unit for carriage onboard. Carrying a damaged unit could potentially increase the risk of thermal runaway.
Owners should also keep in mind that when smaller BESS units are being carried inside containers, they should request the shipper to provide evidence showing that the BESS units are suitably lashed.
Varying quality of information in safety data sheetsInformation contained in the safety data sheets (SDS) and additional guidance by shippers and manufacturers are vital to better understand the overall risks associated with transporting BESS at sea. In our experience, the quality and depth of information can vary depending on the manufacturer and the shipper.
As an example, for one of the shipments the owner was provided with detailed documentation on various aspects of BESS, including lifting, securing, and firefighting, whereas for another shipment a very generic SDS was provided with no cargo-specific guidance. Where owners feel that sufficient details have not been provided by the shipper, they should request for such to be made available.
Another point to note is that since BESS units are primarily built to function on land, the guidance contained in SDS, and other documents provided, may not be applicable to sea transportation. As such, owners are advised to seek additional guidance from shippers on this.
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