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 #11-0265 ([A2Z Test Lab a division of MAI] [Mr. Arvin Blank])

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

Interpretation Response Details

Response Publish Date:

Company Name: A2Z Test Lab a division of MAI

Individual Name: Mr. Arvin Blank

Location State: FL Country: US

View the Interpretation Document

Response text:

December 2, 2011



Mr. Arvin Blank

Environmental Engineering Manager

A2Z Test Lab a division of MAI

220 Power Court

Sanford, Florida 32771

Reference No. 11-0265

Dear Mr. Blank:

This is in response to your October 26, 2011 letter pertaining to the testing of batteries in accordance with the United Nations (UN) Manual of Test and Criteria, 5th revised edition. You reference Section which requires cells and batteries to meet the requirement of the T2 " Thermal Shock Test. This test requires there is no mass loss, no leakage, no venting, no disassembly, no rupture, and no fire if the open circuit voltage of each cell or battery testing is not less than 90% of its voltage immediately prior to this procedure. You ask the Pipeline and Hazardous Materials Safety Administration (PHMSA) to clarify whether a crack in the outer casing of a battery you tested in accordance with the T2-Thermal Shock Test as show in the attached picture would constitute a "rupture."

The answer is yes. In Section of the UN Manual of Test and Criteria, 5th revised edition, a "rupture" is defined as mechanical failure of a cell container or battery case induced by an internal or external case, resulting in exposure or spillage but not the ejection of solid materials. It is the opinion of this Office that a crack in the case of the battery as depicted in your photograph would constitute a "rupture" and thus, be a failure of the T2- Thermal Shock Test.

I hope this satisfies your request.


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
173.159 Batteries, wet