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Interpretation Response #09-0066 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

April 30, 2009




Mr. Andrew Romach

Regulatory Compliance Manager

URS Corporation

1600 Perimeter Park Drive

Morrisville, NC 27560

Ref. No.: 09-0066

Dear Mr. Romach:

This is in response to your February 20, 2009 letter requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type 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 and are implemented through the provisions of § 173.185 of the HMR. Specifically, you ask if your configuration constitutes a single lithium ion battery pack or separate lithium ion battery packs.

With your letter, you enclose a drawing and describe the configuration of a piece of equipment containing two 9-cell lithium ion battery packs. Each battery pack contains 6.4 grams equivalent lithium content, and each battery pack is equipped with its own safety devices designed to control voltage and current. The battery packs are connected in parallel through a printed circuit board located in a plastic tray. Based on the diagram and information provided, this instrument appears to contain two separate battery packs. You should be aware that effective October 1, 2009, the lithium ion batteries described in your letter must be of a type proven to meet the applicable requirements in the UN Manual of Tests and Criteria (see HM-224C, HM-224E, published August 9, 2007

(72 FR 44929)).

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


April 30, 2009

Regulation Sections

Section Subject
173.185 Lithium cells and batteries