Interpretation Response #11-0143 ([ICC Nexergy] [Mr. David Brongiel])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ICC Nexergy
Individual Name: Mr. David Brongiel
Location State: IL Country: US
View the Interpretation Document
Response text:
August 29, 2011
Mr. David Brongiel
Applications Engineering Manager
ICC Nexergy
4 Westbrook Corporate Center, Suite 900
Westchester, IL 60154
Ref. No.: 11-0143
Dear Mr. Brongiel:
This responds to your June 9, 2011 letter and subsequent telephone conversation with a member of my staff regarding the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a lithium battery pack. In your letter you describe a device that uses three 95 Watt-hour lithium ion battery packs, each of which consists of 24, 1.1 Ah cells in a 4S6P configuration. The three lithium ion batteries described in your letter are electrically connected within the device but utilize a microcontroller to ensure that the battery pack will not activate during transportation. Specifically, you ask if the configuration described in your letter may be considered separate lithium ion batteries under the HMR.
No. Since the three battery packs are electrically connected, the configuration described in your letter meets the definition of a battery as defined in section 38.3 of the United Nations Manual of Tests and Criteria. The definition states that a battery means one or more cells which are electrically connected together by a permanent means, including case, terminals and markings.
The lithium battery described in your letter exceeds the size requirements outlined in § 172.102, Special Provision 188. This battery pack may be transported in conformance with requirements in §172.102, Special Provision 189 by highway or rail only and § 173.185 as Class 9 by highway, rail, vessel and aircraft.
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division
172.102 173.185
Regulation Sections
| Section | Subject |
|---|---|
| 173.185 | Lithium cells and batteries |