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Interpretation Response #12-0097 ([INOVA Geophysical Equipment Ltd.] [Mr. Harold Sackett])

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

Interpretation Response Details

Response Publish Date:

Company Name: INOVA Geophysical Equipment Ltd.

Individual Name: Mr. Harold Sackett

Location State: TX Country: US

View the Interpretation Document

Response text:

June 15, 2012




Mr. Harold Sackett
INOVA Geophysical Equipment Ltd.
850 N Dorothy Drive, STE 504
Richardson, TX 75081

Ref. No.: 12-0097

Dear Mr. Sackett:

This is in response to your April 10, 2012 email requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type testing of lithium ion batteries. The requirements you address are contained in Section 38.3 of the United Nations Manual of Tests and Criteria and are implemented through the provisions of § 173.185 of the HMR.

In your letter you describe an assembly comprised of 1-3 lithium ion battery packs in an aluminum enclosure. Each battery pack is less than 100 Wh and comprised of twelve (12) component cells in a 3s4p configuration. Each battery pack is equipped with individual safety circuits, each with its own connector. The battery packs are tied together when assembled in the aluminum enclosure. Specifically, you ask if your configuration constitutes a single lithium ion battery pack or separate lithium ion battery packs.

Based on your description and the information enclosed with your letter it appears that the assembly described in your letter comprised of two or three electrically connected battery packs in an aluminum enclosure meets the defining criteria for a battery as described in Section 38.3 of the United Nations Manual of Tests and Criteria. The definition states that a battery means one or more cells which are electrically connected together by a permanent means, including case, terminals and markings.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries