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Interpretation Response #05-0193 ([MGA Research Corporation] [Mr. Anthony J. Angello])

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. Anthony J. Angello

Location State: NY Country: US

View the Interpretation Document

Response text:

Jul 11, 2006


Mr. Anthony J. Angello                      Reference No. 05-0193
Quality Manger
Mechanical Engineer
Technical Services Labratory
MGA Research Corporation
1:2790 Main Road
Akron, NY 14001

This is in response to your letter dated June 9, 2005, concerning requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for testing of lithium ion batteries. The specific requirements you address are contained in Section 38.3 of the United Nations Manual of Tests and Criteria (UN Manual) and are implemented through the provisions of 49 CFR 173.185. Your questions are paraphrased and answered below:

Q1. If one cell or battery of a lot fails a test, should an entire lot be retested, or can a replacement be used in its place?

Al. In accordance with Paragraph, if a lithium cell or battery type does not meet one or more of the test requirements, steps shall be taken to correct the deficiency or deficiencies that caused the failure before such cell or battery type is retested. The cells and batteries must be subjected to all tests.

Q2. If a cell or battery fails one test, should the model be retested through all tests, or only the test it failed?

A2. In accordance with Paragraph 38.3.4, each cell and battery type must be subjected to Tests T.1 - T.8. Tests T.1 - T.5 must be conducted in sequence on the same cell or battery, T.7 may be done using undamaged batteries previously used in Tests T.1 - T.5, and Tests T.6 and T.8 should be conducted using not otherwise tested cells or batteries. If a cell or battery fails a test steps shall be taken to correct the deficiency or deficiencies and the battery must be subjected to Tests T.1 - T.8.

Q3. What is the definition of the phrase “solid matter” and term “penetrate” as used in the definition “disassembly” in Paragraph of the UN Manual?

A3. Solid matter is defined as a crystalline material, that is, one in which the constituent atoms are arranged in a three-dimensional lattice, periodic in three independent directions. Penetrate is defined as pass into or through, often by overcoming re The term disassembly, as provided in, can be clarified to mean ejection of solid particles at a force that causes them to tear through or pass through a wire mesh screen placed 25 cm away from the cell or battery.

Q4. Would it be more appropriate to use lead shot or a solid steel bar for impact testing? If a steel bar is used, is any type of dampening material such as rubber, allowed in between the bar and the impact mass?

A4. Paragraph of the UN Manual requires a 9.1 kg mass to be dropped on the sample from a height of 61 ± 2.5 cm. In our opinion, the UN Manual uses the: phrase “a
9.1 kg mass” to indicate that the material must be a single mass such as the steel bar.

Q5. Can a constant current source be substituted for the 12V D.C. power supply for the Forced Discharge test in Paragraph

A5. Yes, provided each cell is force discharged for the time interval (in hours) equal to its rated capacity divided by the initial test current (in Ampere).

Q6. Has the Overcharge testing in Paragraph 3 been met if the required overcharge current can be maintained for a period of 24-hours regardless of the charge voltage?

A6. To fulfill the test procedure and requirements, charge voltage must be as specified in 3 or (b), as applicable. In addition, there must be no disassembly or fire of the rechargeable battery within seven days of the test.

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