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Interpretation Response #10-0173 ([Intertek] [Mr. Rich Byczek])

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

Interpretation Response Details

Response Publish Date:

Company Name: Intertek

Individual Name: Mr. Rich Byczek

Location State: MI Country: US

View the Interpretation Document

Response text:

October 13, 2010




Mr. Rich Byczek

Site Manager


13200 Levan Road

Livonia, MI 48150

Ref. No.: 10-0173

Dear Mr. Byczek:

This is in response to your August 17, 2010, email requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type testing of lithium ion batteries. In your email, you describe a lithium ion battery module comprised of electrically connected cells that serves as a component of a larger lithium battery pack. You state this lithium ion battery module is transported between manufacturing facilities and thus is subject to testing in accordance with the United Nations (UN) Manual of Tests and Criteria. In your email, you note this module is equipped with a protective insulator that prevents external access to the battery terminals. You ask if you must remove the protective insulator to conduct the appropriate tests or note that the terminals are inaccessible.

The specific requirements you address are contained in Section 38.3 of the UN Manual of Tests and Criteria and are implemented through the provisions of § 173.185 of the HMR. Prior to transportation in commerce, the lithium ion battery module must successfully pass all of the applicable tests in Section 38.3 of the UN Manual of Tests and Criteria, including the T.5 (short circuit test) and the T.7 (overcharge test). The lithium battery module must be subjected to all of the appropriate design type tests in the same configuration as when it will be installed in the larger battery pack. In this case if a physical barrier such as a cover must be removed prior to installation in the larger battery pack, it must be removed for design type testing.

I hope this information is helpful. If you have further questions, please contact this office.


Ben Supko

Acting Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries