Lithium-ion batteries now move through Canada’s transportation network in unprecedented volumes, embedded in EVs, forklifts, micro-mobility devices, consumer electronics, and energy-storage systems. As Ontario’s clean-energy manufacturing base grows, carriers are increasingly exposed to lithium-ion freight without always receiving complete or accurate information about the hazards or regulatory requirements. This gap is not a matter of negligence; it reflects how quickly the supply chain is evolving.
The 2023 Flying J explosion in Birmingham, Alabama is a defining example. A trailer containing used lithium-ion batteries was sealed and left to off-gas internally. As volatile gases accumulated, internal pressure exceeded the trailer’s structural capacity. The resulting explosion tore sections of the roof away, ignited nearby containers, and scattered debris across the site. Fire officials confirmed that lithium-ion battery off-gassing created an explosive atmosphere inside the trailer.
This outcome aligns with destructive testing data. When lithium-ion batteries fail, they can release hydrogen, hydrocarbons, carbon monoxide, and other volatile gases, many within known explosive concentration ranges. A single laptop battery in thermal runaway can produce enough flammable gases to blow a typical single-car garage door off its tracks. This has been demonstrated in real-world events and validated in controlled testing.
This is why Special Permits, also called Equivalency Certificates, and specific packaging standards exist. Packaging under UN P908 and LP904 is engineered to contain thermal events, limit heat transfer, isolate components, absorb impact energy, and prevent dangerous gas buildup. The goal is to stop a localized battery failure from escalating into a major incident. These controls work effectively when they are applied as designed.
Under Transport Canada’s Transportation of Dangerous Goods Regulations, lithium-ion batteries fall under Class 9 Miscellaneous Dangerous Goods, linked to the following UN numbers: UN3480 for lithium-ion batteries, UN3481 for batteries contained in or packed with equipment, and UN3090 or UN3091 for lithium-metal batteries. Carriers must ensure documentation accurately reflects the load. If the bill of lading is incomplete, inconsistent, or unclear, the carrier is required to refuse the shipment.
A growing operational issue involves DDR batteries, meaning Damaged, Defective, or Recall units. These batteries require enhanced containment because they are more likely to vent, leak, or enter thermal runaway. They must be transported using P908 or LP904-compliant packaging, or under a Special Permit that authorizes an alternate method. However, across the industry, some organizations hold Special Permits but do not use the packaging or follow the procedures required by those permits. This is often driven by cost pressures, as compliant DDR packaging and neutralizing media can be expensive. But when the packaging does not match the Special Permit conditions, the safety equivalency no longer exists, and the carrier unknowingly absorbs additional risk.
This is not an indictment of shippers or carriers. It reflects the pace of change in lithium-ion logistics and the complexity of the regulatory framework. The key point is that having a Special Permit does not guarantee safety unless the specific permit conditions are followed precisely.
Anyone handling, offering, or transporting lithium batteries must hold valid TDG Part 6 training. In the aftermath of any incident, investigators are mandated to review classification accuracy, packaging compliance, and training records.
The fundamental fact remains: lithium-ion batteries are not conventional cargo. They can create explosive atmospheres in confined spaces, and the packaging standards exist because these hazards have been repeatedly
proven, not theorized.
CCR conducts destructive testing, failure analysis, and lithium-ion safety research that informs standards and best practices used across industry and government. This work helps organizations understand the technical basis behind these requirements and why proper packaging, correct permit use, and accurate classification are essential for protecting drivers, staff, and the public.
Randy Narine
President & CEO
Engineering Confidence in Clean Energy