CINS Recommendation Paper - IMDG SP188 Lithium-Ion Batteries

CINS has published a new Recommendation Paper calling for reform of IMDG Code Special Provision 188 (SP188) for lithium-ion batteries. 

Drawing on incident data and operational experience, the paper argues that SP188 should no longer function as a largely invisible exemption and proposes several safety-focused changes. 

Through this paper, CINS is calling for a fundamental shift in SP188 controls, moving from limited oversight towards mandatory declaration, container-level limits, and greater supply chain transparency to address the growing fire risks associated with lithium-ion battery shipments. If adopted, the recommendations would significantly change how lithium-ion batteries are booked, declared, accepted, stowed, and managed throughout the transport chain. 

The overall objective is to move SP188 shipments from being largely “invisible” cargo to cargo that is “visible and traceable”. 

Key Safety Changes Proposed for SP188 Lithium-Ion Batteries 

1. Mandatory Declaration for All Lithium-Ion Batteries 

   The paper's primary recommendation is that all lithium-ion battery shipments should be subject to a mandatory dangerous goods declaration, including batteries currently transported under SP188 exemptions. This would improve visibility and traceability throughout the transport chain.

2. CTU-Level Quantity Limits 

   A new Container Transport Unit (CTU) threshold model is proposed to prevent the unlimited accumulation of SP188 batteries within a single container. The objective is to reduce the consequences of thermal runaway and container fires. 

3. Threshold & full IMDG compliance 

   CINS recommends limiting SP188 relief to consignments containing up to 20 kg gross battery mass per CTU. Shipments above this threshold would be required to comply fully with IMDG Code dangerous goods provisions and declaration requirements. 

4. Enhanced Supply Chain Visibility 

   The paper emphasizes that SP188 relief should only remain available where the maritime transport chain maintains adequate visibility, traceability, and control of lithium-ion batteries. Treating SP188 cargo as ordinary non-dangerous cargo is described as creating an operational blind spot.

5. Based on key operational experience and incident data

   1. Misdeclaration and undeclared battery cargo.
   2. Poor packaging and documentation compliance. 
   3. Battery quality concerns and thermal runaway incidents.
   4. Challenges in stowage planning, emergency response, and firefighting due to lack of cargo visibility 

The proposed SP188 reforms should give carriers, terminals, and emergency responders improved visibility on the Li-ion battery shipments and aid in better informed stowage planning as well as safer emergency response planning.