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Interpretation Response #05-0036 ([Wiley Rein & Fielding LLP] [Mr. George A. Kerchner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wiley Rein & Fielding LLP

Individual Name: Mr. George A. Kerchner

Location State: DC Country: US

View the Interpretation Document

Response text:

Mar 18, 2005


Mr. George A. Kerchner                      Reference No: 05-0036
Wiley Rein & Fielding LLP
1776 K Street NW
Washington, DC 20006

Dear Mr. Kerchner:

This is in response to your letter requesting clarification on the testing of lithium batteries and cells. Specifically you asked for clarification of the requirements of the UN Thermal Test (Test 2) under section of the United Nations Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria for determining the percentage mass loss criteria for lithium and lithium ion batteries and cells.

The method used for determining the “Percentage Mass Loss Criteria” of a lithium battery or cell observed during the UN lithium battery thermal test (Test 2) is ] to the mass loss that is directly attributed to the lithium battery or cell. Mass loss that can be attributed to packaging components (e.g., plastics, foam, potting compound, tape, etc.) should not be considered in calculating the percent of mass loss for the UN Thermal Test (Test 2).

I hope this information is helpful. Please contact us if you require additional assistance



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries