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Interpretation Response #13-0126 ([Naval Surface Warfare Center Energy Power & Interconnect Technologies Division] [Mr. Mark Tisher])

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

Interpretation Response Details

Response Publish Date:

Company Name: Naval Surface Warfare Center Energy Power & Interconnect Technologies Division

Individual Name: Mr. Mark Tisher

Location State: IN Country: US

View the Interpretation Document

Response text:

August 21, 2013


Mr. Mark Tisher
Crane Division
Naval Surface Warfare Center
Energy Power & Interconnect Technologies Division
300 Highway 361, Bldg. 3235 GSX
Crane, IN 47522-5001

Ref. No.: 13-0126

Dear Mr. Tisher:

This responds to your June 13, 2013 email and subsequent conversation with a member of my staff requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design testing of lithium ion batteries.  The requirements you address are contained in Section 38.3 of the United Nations (UN) Manual of Tests and Criteria and are implemented through the provisions of § 173.185 of the HMR.  In your letter and in telephone conversations with my staff, you described a cylindrical battery comprised of 35 individual cells.  The battery is inserted into an aluminum housing that is part of a battery powered device.  The device with the batteries is then placed into a case for shipping.  You asked if you could conduct the T3 (shock) and the T4 (vibration) tests with the battery installed in the aluminum housing or in a transit box because the battery itself is not equipped with mounts to secure it to the testing machine.  

Each test in Section 38.3 must be conducted on the battery itself without equipment or packaging.  In the situation you described, the battery must be subjected to each of the tests, including the shock and the vibration tests outside of the device or any packaging.

I hope this answers your inquiry.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries