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Interpretation Response #10-0264 ([Liquid Robotics, Inc.] [Mr. Roger Hine])

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

Interpretation Response Details

Response Publish Date:

Company Name: Liquid Robotics, Inc.

Individual Name: Mr. Roger Hine

Location State: CA Country: US

View the Interpretation Document

Response text:

February 18, 2011




Mr. Roger Hine
President and CEO
Liquid Robotics, Inc.
1329 Moffett Park Drive
Sunnyvale, CA 94089

Ref. No.: 10-0264

Dear Mr. Hine:

This responds to your December 22, 2010 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium ion battery powered devices. Specifically, you ask us to confirm your understanding that the battery packs described in your letter are considered separate lithium ion batteries and meet all of the applicable requirements of § 172.102(c), Special Provision 188. In addition to your letter, you enclose a drawing showing the configuration of the lithium ion battery packs.

According to your letter, the device contains seven 95 Wh lithium ion batteries consisting of twelve 2.2 ampre hour cells in a 4S3P configuration. Your letter states that each of the lithium ion cells and the battery pack both meet the applicable tests outlined in the UN Manual of Tests and Criteria. The seven lithium ion battery packs are mounted in an aluminum housing that is securely attached to a drybox designed to both mechanically isolate and prevent any movement of the batteries during transport or operation. Your letter further states that each of the battery packs are electrically isolated from each other through a set of solid state switches that can only be activated through the use of an external plug inserted into its mating jack on the drybox. The drybox will be shipped without the plug inserted and the plug secured in a manner to prevent accidental activation. Additionally, a distinct warning label affixed on the box instructs users not to transport the device with the plug inserted into the jack.

Based on the information described in your letter, it is the opinion of this office that when the plug is removed from the mating jack, the battery packs described in your letter are electrically isolated from

each other and would constitute separate lithium ion battery packs. Further, the steps taken to prevent damage, short circuits and accidental activation during transport appear to meet the requirements of § 172.102, Special Provision 188.

I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division.


Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division

172.102(c) SP 188

Regulation Sections

Section Subject
173.185 Lithium cells and batteries