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Interpretation Response #11-0056 ([Raytheon Network Centric Systems Integrated Communication Systems] [Ms. Janette Parker])

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

Interpretation Response Details

Response Publish Date:

Company Name: Raytheon Network Centric Systems Integrated Communication Systems

Individual Name: Ms. Janette Parker

Location State: IN Country: US

View the Interpretation Document

Response text:

June 16, 2011


Ms. Janette Parker
Project Manager
Raytheon Network Centric Systems
Integrated Communication Systems
1010 Production Road
M/S D2-12
Fort Wayne, IN 46808-4106

Ref. No.: 11-0056

Dear Ms. Parker:

This responds to your March 4, 2011 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a lithium ion battery. Specifically, you ask us to confirm your understanding that the battery pack described in your letter meets all of the applicable requirements of § 172.102(c), Special Provision 188. In addition to your letter, you enclosed a copy of a test report for a 3-cell battery pack showing compliance with the applicable tests outlined in the United Nations (UN) Manual of Tests and Criteria and a drawing showing the configuration of the lithium ion battery pack.

According to your letter, you intend to ship a mount assembly for a lithium ion battery powered radio. You described the mount assembly as "Lithium ion batteries contained in equipment, UN3481, PG II." For your information, the term "equipment" as it is used in the proper shipping name "Lithium ion batteries contained in equipment" refers to the apparatus or device that performs a function requiring the lithium ion batteries. A lithium ion battery pack placed into a mount and transported without the radio the battery pack is intended to power is properly described as "Lithium ion batteries, UN3480, PG II."

The mount assembly contains three lithium ion battery packs connected in parallel and each lithium ion battery pack contains three cells connected in series. The resulting voltage and capacity of the nine-cell battery pack is 9.6 V and 4200 mAh respectively or approximately 40.32 Wh. In your letter, you state that each battery pack contains two distinct means of protection against short circuiting and internal damage due to overcharge or over discharge. Further, the battery packs are securely installed into the mount and placed into a strong outer packaging.

Based on the information provided in your letter, the battery pack meets the appropriate size limits for lithium ion cells and batteries as required by § 172.102(c), Special Provision 188 and the battery pack appears to be adequately packaged and protected from short circuits and damage. However, in accordance with paragraph d. of Special provision 188, the 9-cell battery pack described in your letter must be of a type proven to meet the applicable tests in the UN Manual of Tests and Criteria. The test report you provided with your letter describes the component batteries, but not to the completed battery pack placed in the mount assembly and prepared for transport. The 9-cell lithium battery pack is subject to the UN tests regardless even though the component cells or batteries have been tested.

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


Ben Supko
Chief, Standards Development Branch
Standards and Rulemaking Division

172.102 SP 188

Regulation Sections

Section Subject
173.185 Lithium cells and batteries