Article Summary
Taking a lithium battery safety program from a single site to global operations exposes a different set of problems than building the program in the first place. John Redman, COO at Americase International, explains why scaling should be done regionally rather than uniformly — right-sizing the program for North America, South America, Europe, and Asia, and identifying the people in each region who act as the “antenna function” watching local regulatory change. He also names the four pitfalls that most often derail lithium battery programs as they scale: siloed departments that disconnect engineering and R&D from compliance, inadequate oversight of suppliers whose batteries may not carry proper UN 38.3 certification, one-time training events treated as sufficient instead of ongoing development, and poor record-keeping that leaves corrective actions undocumented and unproven.
Right-Sizing Your Program by Region
Scaling a hazmat program correctly should be done at the regional level, not applied uniformly across a global footprint. That means looking at your program separately for North America, then South America, then Europe, then Asia — because the regional complexities and the regional regulations are genuinely different in each. The right place to start is understanding where each region actually stands today.
From there, the critical step is identifying the people within each region who act as your “antenna function” — the ones watching the regulations, accumulating information, and providing interpretations grounded in knowledge of your global operations, so that regulations are applied consistently across the organization rather than differently in every region. Just as important is building the connectivity across continents: partnership, collaboration, and communication whenever there’s a regulatory change, a new interpretation, or a risk surfacing anywhere in the business.
A compliance division with genuinely global capability — one that can support, manage, and communicate regulations, systems, and procedures consistently — is what makes that scaling work.
Common Pitfall #1: Siloed Departments
As lithium battery use expands inside an organization — into new components, robotics, or drone technology, for example — engineering and R&D divisions often spin up their own subdivisions working with batteries independently of the compliance division. Breaking down those silos, so that anyone touching hazardous materials or dangerous goods is connected back to a single compliance function, is critical. It’s one of the most common pitfalls in scaling lithium battery programs.
Common Pitfall #2: Inadequate Supplier Oversight
If a supplier is moving material for you, sending you material, or sourcing product on your behalf, gaps in oversight become gaps in your own compliance. A common scenario: an R&D team contracts a battery developer overseas to build a battery for a specific project, and that battery isn’t actually UN 38.3 certified. Shipping that battery — particularly by air — creates real regulatory risk and potential legal exposure. The same logic applies domestically: suppliers who transport, handle, or dispose of your lithium batteries in a way that doesn’t align with your dangerous goods responsibilities can create co-liability exposure the moment something goes wrong. Supplier oversight has to be aligned directly with your compliance division, not treated as someone else’s problem.
Common Pitfall #3: One-Time Training Instead of Ongoing Development
A common mistake is running a single training event — often within an employee’s first 90 days — and assuming that covers their ongoing responsibilities. Hazmat and dangerous goods training has a recurring need every few years, and every time a regulation changes, there has to be a documented process for recommunicating that change back to the team members it affects. That documentation isn’t just about proving the training happened; it’s what confirms your team members are actually properly equipped. The goal is moving from a one-time training event to an ongoing, periodic training and development process for everyone engaged in hazmat safety.
Common Pitfall #4: Poor Record-Keeping
Many organizations implement a procedure or an audit protocol, identify real issues through it, and then the corrective action process quietly fails — nothing actually gets fixed, or documentation doesn’t reflect what was implemented in the field. That gap creates real liability: a record showing a compliance issue was identified but not verifiably resolved is often worse than no record at all. The two most commonly cited risks here are lack of training documentation and lack of shipping documentation retention — alongside gaps in test summary reports, SDS, and ERG information. Record-keeping discipline across all of it is essential.
Building the Connective Tissue Across Regions
The organizations that scale successfully tend to combine standardized core processes with regional flexibility — centers of excellence paired with field deployment, so every region benefits from consistent global standards while still having the local expertise to apply them correctly.
How Americase Helps Companies Scale Safely
Every one of these pitfalls is a version of the same underlying problem: a program that worked at one site doesn’t automatically translate to global operations without deliberate structure. HazMat Safety Consulting’s bench of former regulators and international rulemaking experts is built specifically to help organizations navigate that regional regulatory complexity, while Americase’s containment solutions and Fulcrum Testing’s validation work ensure that whatever program you’re scaling is actually backed by tested, proven solutions in every region you operate.
By John Redman, Chief Operating Officer, Americase International
FAQ Section
By right-sizing the program regionally rather than uniformly — assessing North America, South America, Europe, and Asia separately given their distinct regulatory environments — and combining standardized core processes with regional flexibility, such as centers of excellence paired with local field deployment.
It refers to the people identified within each region who watch local regulatory developments, gather information, and provide interpretations grounded in knowledge of the organization’s global operations, ensuring regulations are applied consistently company-wide.
Four stand out: siloed departments that disconnect engineering and R&D from the compliance division, inadequate supplier oversight, one-time training events treated as sufficient instead of ongoing development, and poor record-keeping and follow-through on corrective actions.
Suppliers sourcing or handling batteries on an organization’s behalf may not be UN 38.3 certified, particularly for R&D projects sourced overseas, creating regulatory and legal exposure. Domestic suppliers handling, transporting, or disposing of batteries out of alignment with dangerous goods responsibilities can also create co-liability risk.
Hazmat and dangerous goods regulations change periodically, and there’s a recurring need to retrain and redocument understanding every few years. A single onboarding session doesn’t account for regulatory change or confirm that team members remain properly equipped over time.
Lack of training documentation and lack of shipping documentation retention are the two most frequently cited risks, alongside gaps in test summary reports, safety data sheets (SDS), and emergency response guide (ERG) information.