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Interpretation Response #08-0028 ([Raytheon Missile Systems] [Mr. Steve Jacob])

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

Interpretation Response Details

Response Publish Date:

Company Name: Raytheon Missile Systems

Individual Name: Mr. Steve Jacob

Location State: AZ Country: US

View the Interpretation Document

Response text:

July 9, 2008

Mr. Steve Jacob

Raytheon Missile Systems

11651 N. Via De La Verbenita

Oro Valley, AZ 85737

Ref. No. 08-0028

Dear Mr. Jacob:

This responds to your January 24, 2008 request for clarification on a container designed to transport a lithium battery under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

According to your request, you have designed a container to ship a lithium ion battery to be used by the military. The container will contain a total of 18 batteries connected in three banks. Each of the 18 batteries consists of 25 cells in a plastic, sealed, waterproof enclosure with a vent. Each bank of six batteries is tightly assembled and enclosed in a strong aluminum box; the three boxes are assembled together to make a single unit. The outside container is waterproof and includes a charging device connected to the large battery assembly. The container includes mechanisms to protect the battery assembly from shock and vibration to prevent short circuits and reverse charging. The total weight of the battery assembly is 26 kg; the total weight of the assembly with aluminum enclosures is 41 kg. The battery assembly contains a total of 0.315 kg of lithium.

Your questions are paraphrased and answered as follows:

Q1. Does this configuration conform to the HMR for transportation by highway?

What test requirements apply to the container? Is a liner required?

A1. The battery assembly must conform to the requirements in §173.185 of the HMR. Thus, among other requirements, the battery assembly must be tested in accordance with the UN Manual of Tests and Criteria and must be packaged in combination packagings conforming to the requirements of Subparts L and M of Part 178 at the Packing Group II performance level. A liner is not required if the container is waterproof. Packaging test requirements and pass/fail criteria are in Subpart M of part 178.

Q2. May the battery be connected and charging during transportation?

A2. No. The terminals must be protected from damage and short circuits. Batteries connected and charging during transportation may pose a short circuit hazard.

If you cannot comply with the §173.185 requirements, you must apply for an Approval from the Office of Special Permits and Approvals. Procedures for applying for an Approval are in Subpart H of Part 107 in the HMR.

I hope this answers your inquiry.


Susan Gorsky

Regulations Officer

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries