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 38.3.4.2.3 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 38.3.2.2 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.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.159
Regulation Sections
| Section | Subject |
|---|---|
| 173.159 | Batteries, wet |