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Interpretation Response #08-0051 ([Phillips Medical Systems] [Mr. Alan Greenstein])

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

Interpretation Response Details

Response Publish Date:

Company Name: Phillips Medical Systems

Individual Name: Mr. Alan Greenstein

Location State: WA Country: US

View the Interpretation Document

Response text:

June 11, 2008

Mr. Alan Greenstein

Phillips Medical Systems

2301 5th Ave., Suite 200

Seattle, WA 98121

Ref. No.: 08-0051

Dear Mr. Greenstein:

This is in response to your February 29, 2008 letter concerning the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to two configurations of lithium metal cells mounted into casing. Specifically you ask if your configurations of lithium metal cells constitute a lithium battery or a collection of individual cells.

In your letter, you enclose drawings and describe the configurations for two modules that contain several lithium metal cells, each containing less than 2 grams of lithium. The individual cells are permanently mounted in a module. The aggregate lithium content of the cells contained in each module is more than 2 grams. You state no electrical connections exist between the cells until the module is installed in the equipment.

Provided no electrical connections exist between the cells, the configurations described in your letter would constitute a collection of individual cells and not a battery. Once the module is installed into the device and electrical connections are made, these configurations should be described and transported as a lithium battery contained in equipment. You should note once installed in the device, the lithium metal cells are connected and the module constitutes a battery.

Prior to transportation in commerce, the cells in the module or the lithium battery installed in the device must meet all applicable HMR requirements including UN design type testing.

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