Interpretation Response #10-0135 ([Naval Surface Warfare Center Energy Power & Interconnect Technologies Division] [Mr. Mark Tisher])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Naval Surface Warfare Center Energy Power & Interconnect Technologies Division
Individual Name: Mr. Mark Tisher
Location State: IN Country: US
View the Interpretation Document
Response text:
August 2, 2010
Mr. Mark Tisher
Crane Division
Naval Surface Warfare Center
Energy Power & Interconnect Technologies Division
300 Highway 361, Bldg. 3235 GSX
Crane, IN 47522-5001
Ref. No.: 10-0135
Dear Mr. Tisher:
This responds to your June 10, 2010 letter and subsequent conversation with a member of my staff requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type testing of lithium ion batteries. Specifically, you ask if a device containing a lithium battery composed of either four or seven modules must be tested in accordance with the UN Manual of Tests and Criteria when the cells and the modules are of a type proven to meet each of the appropriate tests in accordance with the UN Manual of Tests and Criteria.
In your letter, you state the two configuration of the battery in the device differ only in the number of battery modules contained within the battery. Specifically, one battery contains four modules and the other contains seven. Each battery module containing 446.1 grams of lithium consists of 43 DD cells connected in series. The cells contained in the module, and the module are both of a type proven to meet each of the applicable tests described in Section 38.3 of the UN Manual of Tests and Criteria. The modules remain electrically isolated during transport and the battery modules can only be connected after a deliberate sequence expected to occur after transportation has ended.
Provided no electrical connections exist between the modules, the configurations described in your letter would constitute individual batteries contained in equipment and would not require additional testing.
I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.185
Regulation Sections
| Section | Subject |
|---|---|
| 173.185 | Lithium cells and batteries |