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.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.185
Regulation Sections
| Section | Subject |
|---|---|
| 173.185 | Lithium cells and batteries |