Interpretation Response #10-0199 ([Britton & Associates, S.C.] [Mr. Larry J. Britton])

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

Interpretation Response Details

Response Publish Date: 10/21/2010

Company Name: Britton & Associates, S.C.

Individual Name: Mr. Larry J. Britton

Location State: WI Country: US

View the Interpretation Document

Response text:

October 21, 2010

Mr. Larry J. Britton

Britton & Associates, S.C.

735 North Water Street

16th Floor West

Milwaukee, WI 53202

Ref. No.: 10-0199

Dear Mr. Britton:

This is in response to your September 3, 2010, 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. You describe a single lithium ion battery comprised of electrically connected cells weighing approximately 650 lbs and a watt-hour (Wh) rating of 28,000 Wh. Additionally, you state that the component cells will pass each of the applicable tests outlined in the 5th revised edition of the UN Manual of Tests and Criteria. Specifically you ask if the battery described in your letter must additionally pass each of the applicable tests outlined in the UN Manual of Tests and Criteria.

In accordance with the UN Manual of Tests and Criteria, a lithium battery assembly in which the aggregate lithium content of all anodes, when fully charged, is more than 500 g, or in the case of a lithium ion battery, a Watt-hour rating of more than 6,200 Watt-hours is comprised of electrically connected batteries that have passed all applicable tests does not need to be tested if it is equipped with a system capable of monitoring the battery assembly and preventing short circuits, or over discharge between the batteries in the assembly and any overheat or overcharge of the battery assembly.

The provision described above applies to a battery assembly composed of electrically connected batteries that have passed all applicable tests. Since the battery described in your letter is assembled from individually tested cells and not individually tested batteries, the battery described in your letter must meet all of the applicable tests in the UN Manual of Tests and Criteria. While each of



the cells that form the battery described in your letter may pass each of the applicable design type tests, there is no evidence of the ability of the battery to pass the applicable tests.

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

Sincerely,

Ben Supko

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.185

Regulation Sections