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Interpretation Response #09-0303 ([Electrochem Solutions] [Mr. Todd Sweetland])

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

Interpretation Response Details

Response Publish Date:

Company Name: Electrochem Solutions

Individual Name: Mr. Todd Sweetland

Location State: MA Country: US

View the Interpretation Document

Response text:

February 24, 2010




Mr. Todd Sweetland

Product Engineering Manager

Electrochem Solutions

670 Paramount Drive

Raynham, MA 02767

Ref. No.: 09-0303

Dear Mr. Sweetland:

This responds to your December 4, 2009 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of a lithium battery powered device. Specifically you ask if the design features described in your letter adequately prevent accidental operation of the device during transport.

In accordance with § 173.185, electrical devices with lithium batteries installed are required to be packed to prevent short circuits and unintentional activation during transport. According to your letter, this device utilizes a single connector that must be manually installed in order to activate. During transport, a red connector is installed in the device to maintain its waterproof design and ensure the device will not activate. When the device is ready for operation, a technician will remove the red connector and install the green connector. You further state the device can only operate when the green connector is installed.

The HMR do not prescribe specific means to meet the requirement to prevent accidental activation. However, the method described in your letter appears to meet the intent of this requirement.

I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries