Hi,
The intended tone was of panic because that original letter was written to a group of other e-bike dealers and battery sellers I know. They tend to be an individualistic lot who don't like working together towards any common goal. But tackling the issue is going to take concerted effort.
The first half of my letter (about shipping batteries) I'm quite sure about; I know of someone who is being fined for this.
The second half is a logical extension of the "rule." While I totally agree with you that end users
should be able to use these devices without getting in trouble, I've yet to see anywhere that it is written such that a battery classified as a "large li-ion" battery by DOT standards, is in any way exempt, even if installed in the end-user device. Do I think DOT is going to be knocking on all our doors tomorrow? No. But I point this out because it shows the lunacy of this ruling. Basically, the DOT has decided that any quantity of lithium above 25g is a hazardous substance akin to a tanker truck - not akin to the ORM-D. Regardless of type, configuration, etc. Please show me where the ruling says I'm wrong - I seriously want to be wrong.
The last thing I want is to be dealing with this. In fact, just for raising the issue, I've caught quite a bit of flack already from people who "don't believe me" or tell me "I am being manipulated" or that it is a "government conspiracy" or a "large battery manufacturer conspiracy."
However, I think it is much simpler than that. There have been serious lithium fires (mostly LiCoO2). The large manufacturers of those banded together and got themselves a lobbyist to represent them, so that they didn't get shut down completely. Therefore, when the rules were made, their interests were represented.
But since us ebike folks are way too independent and libertarian and "government conspiracy" oriented, nobody got together. The end result is our interests were not represented in the rule making. And so the rule completely ignores our needs and interests as sellers and users of ebikes.
My goal with all of this is to get some folks riled up so we can actually get something done about it. Because, you may laugh at the example I gave above, but here's the reality. There are likely to be more battery incidents as these get more popular. It doesn't matter whether those incidents are big lithium fires (as the case with LiCoO2 or Lithium metal batteries), or little short-circuit type incidents like the one that got someone I know fined (with a LiFePO4). As of right now, the DOT treats them all as the same thing: evidence that lithium ion batteries are "dangerous." The more such "evidence" accumulates, without the DOT hearing from people like us, the more likely that the rules will get even more strict in the future. That will affect all of us, as both sellers and users of these technologies (I am both). If nothing else, these are going to increase costs for everyone. I already know of several manufacturers that are starting to get the testing done, and you can believe me that they will pass the costs on to you (and me). It is not cheap.
That's why I'm riled up about it.
lcyclist said:
E-BikeKit.com said:
And it gets worse.
If the DOT ever decides to enforce the letter of this law, it would shut down what all of us are doing.
Why the sound of panic? DOT is classifying these so called "hazardous materials" for shipping. In the US, we already classify materials considered hazardous/flammable/poisonous, etc by an appropriate label for shipping.
For example, merchants ship hazardous materials to my house via FEDEX all the time. These hazardous materials are small arms ammunition (rifle and handgun cartridges). The shipping container must be labeled ORM-D and that the shipper must be trained and certified to ship these hazardous material, that's all. Of course it is not illegal to ship ammo but merchants/sellers must abide by the rule (training, certification and proper label/classification). And DOT enforces these rules; violate them and risk fines.
As an end user, I don't have to classify my ammo as ORM-D when I bring my ammo to the shooting range and it is not illegal, at least in Arizona, to carry my ammo in my vehicle for transportation.
