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 #11-0025 ([Securaplane Technologies, Inc.] [Mr. Rod Iverson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Securaplane Technologies, Inc.

Individual Name: Mr. Rod Iverson

Location State: AZ Country: US

View the Interpretation Document

Response text:

March 15, 2011




Mr. Rod Iverson

Securaplane Technologies, Inc.

10900 N. Stallard Place

Tucson, AZ 85737

Ref. No.: 11-0025

Dear Mr. Iverson:

This responds to your January 31, 2011 email requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design type testing requirements for a lithium ion battery. According to your letter, your company, located in Tucson, AZ contracted with another company based in San Jose, CA to assemble and test a lithium ion battery pack in accordance with the applicable requirements of United Nations (UN) Manual of Tests and Criteria. The battery packs assembled by this company passed the applicable tests. You wish to continue manufacturing this battery pack at your Tucson, AZ facility and you ask us to confirm your understanding that your company may manufacture lithium ion batteries that are identical to the previously manufactured and tested lithium ion batteries without subjecting them to additional testing.

The tests outlined in the UN Manual of Tests and Criteria for lithium batteries are design type tests. Provided the lithium ion batteries you intend to manufacture are identical to a previously tested design type, additional testing is not required.

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

173.159, 173.185

Regulation Sections

Section Subject
173.185 Lithium cells and batteries