USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0135 ([Naval Surface Warfare Center Energy Power & Interconnect Technologies Division] [Mr. Mark Tisher])

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

Interpretation Response Details

Response Publish Date:

Company Name: Naval Surface Warfare Center Energy Power & Interconnect Technologies Division

Individual Name: Mr. Mark Tisher

Location State: IN Country: US

View the Interpretation Document

Response text:

August 2, 2010

 

 

 

Mr. Mark Tisher

Crane Division

Naval Surface Warfare Center

Energy Power & Interconnect Technologies Division

300 Highway 361, Bldg. 3235 GSX

Crane, IN 47522-5001

Ref. No.: 10-0135

Dear Mr. Tisher:

This responds to your June 10, 2010 letter and subsequent conversation with a member of my staff requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type testing of lithium ion batteries. Specifically, you ask if a device containing a lithium battery composed of either four or seven modules must be tested in accordance with the UN Manual of Tests and Criteria when the cells and the modules are of a type proven to meet each of the appropriate tests in accordance with the UN Manual of Tests and Criteria.

In your letter, you state the two configuration of the battery in the device differ only in the number of battery modules contained within the battery. Specifically, one battery contains four modules and the other contains seven. Each battery module containing 446.1 grams of lithium consists of 43 DD cells connected in series. The cells contained in the module, and the module are both of a type proven to meet each of the applicable tests described in Section 38.3 of the UN Manual of Tests and Criteria. The modules remain electrically isolated during transport and the battery modules can only be connected after a deliberate sequence expected to occur after transportation has ended.

Provided no electrical connections exist between the modules, the configurations described in your letter would constitute individual batteries contained in equipment and would not require additional testing.

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