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Interpretation Response #01-0320 ([EnerSys Inc.] [Mr. Jeffrey S. Koller])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: EnerSys Inc.

Individual Name: Mr. Jeffrey S. Koller

Location State: PA Country: US

View the Interpretation Document

Response text:

February 20, 2002


Mr. Jeffrey S. Koller                      Reference No. 01-0320
EnerSys Inc.
P.O. Box 14145
Reading, PA 19605

Dear Mr. Koller:

This responds to your December 12, 2001 letter requesting clarification on testing requirements for nonspillable batteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if testing is required if you change the post seal design of this battery type.

According to your letter and enclosed drawing, the existing design for your lead acid battery posts was certified as nonspillable by a third party testing facility. hi the drawing, you show a lead acid battery post seal design that your company is planning on using.  You are requesting clarification on whether testing is required if the post seal design for the lead acid nonspillable battery is changed.

A nonspillable electric storage battery must be capable of passing the vibration and pressure differential tests without leakage of battery fluid from the battery as provided in § 173.159(d)(3). Leakage of any fluid, oozing, dripping, or seeping, etc. is considered as failure of the tests.  Based on information provided, it is the opinion of this Office that the new post seal design is sufficiently different that testing is required to ensure that the batteries meet requirements in § 173.159(d)(3).

I hope this answers your inquiry.



Delmer Billings
Chief, Standards Development
Office of  Hazardous Materials Standards


Regulation Sections

Section Subject
173.159 Batteries, wet