Interpretation Response #10-0017 ([MGA Research Corporation] [Mr. Michael Greiner])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: MGA Research Corporation
Individual Name: Mr. Michael Greiner
Location State: NY Country: US
View the Interpretation Document
Response text:
March 16, 2010
Mr. Michael Greiner
MGA Research Corporation
12790 Main Road
Akron, NY 14001
Ref. No.: 10-0017
Dear Mr. Greiner:
This is in response to your January 26, 2010 email requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type testing of lithium ion batteries. The specific requirements you address are contained in Section 38.3 of the 5th Revised Edition of the United Nations Manual of Tests and Criteria. Currently, the HMR reference the 4th Revised Edition of the United Nations Manual of Tests and Criteria. PHMSA proposed to incorporate the 5th revised edition in a notice of proposed rulemaking published on January 11, 2010 (HM-224F; 75 FR 1301).
Your letter describes two lithium ion hybrid electric vehicle battery assemblies consisting of electrically connected cells and modules. Your questions have been paraphrased and answered as follows:
Q1. You ask us to confirm your understanding of the appropriate number and condition of cells and batteries required to be tested in accordance with the 5th Revised Edition of the United Nations Manual of Tests and Criteria.
A1. The information you provided in your letter pertaining to the number and condition of lithium cells and batteries required to complete the design type tests outlined in the 5th Revised Edition of the United Nations Manual of Tests and Criteria is correct.
Q2. Provided the lithium battery modules or lithium battery assemblies are internally disconnected when offered for transportation and transported, is the lithium battery module or lithium battery pack subject to the UN design type tests?
A2. Provided the lithium cells comprising the battery module or the lithium battery modules comprising the battery assembly are not electrically connected, then each component is considered an individual battery for the purposes of testing. However, once electrically connected, the entire battery module or battery assembly must be tested as a single battery.
Q3. If the battery cells and modules successfully pass the UN design type tests, is the battery assembly subject to testing?
A3. The answer to this question depends on the size of the battery assembly. The 4th revised edition of the UN Manual of Tests and Criteria does not require further testing of battery assemblies comprised of successfully tested cells and batteries when the aggregate lithium content of all anodes, when fully charged, is more than 500 g or in the case of a lithium ion battery, is more than 6200 Watt-hours provided certain conditions are met. This means that battery assemblies with not more than 500 g aggregate lithium content or in the case of a lithium ion battery, is not more than 6200 Watt-hours are subject to each of the appropriate tests in the quantity indicated.
The 5th revised edition would permit alternative testing for battery assemblies in which the aggregate lithium content of all anodes, when fully charged, is not more than 500 g, or in the case of a lithium ion battery, a Watt-hour rating of not more than 6200 Watt-hours, that is assembled from cells or batteries that have passed all applicable tests. In this case, one battery assembly in a fully charged state must be tested under Tests 3, 4, and 5, and, in addition, Test 7 in the case of a rechargeable battery assembly. For a rechargeable battery assembly, the assembly shall have been cycled at least 25 cycles.
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
172.101, 173.85