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Interpretation Response #13-0213 ([Lockheed Martin MST] [Mr. Kevin Unger])

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

Interpretation Response Details

Response Publish Date:

Company Name: Lockheed Martin MST

Individual Name: Mr. Kevin Unger

Location State: NY Country: US

View the Interpretation Document

Response text:

January 28, 2014

Mr. Kevin Unger
Lockheed Martin MST
1801 State Route 17C
Mail Drop 0574
Owego, NY 13827

Reference No.: 13-0213

Dear Mr. Unger:

This is in response to your November 11, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  The specific requirements you address are contained in Section of the United Nations (UN) Manual of Tests and Criteria and are implemented through the provisions of 49 CFR 173.185. Specifically you ask if adding wire leads from the anode and cathode of a single cell battery would constitute a change to the cell design that would require the battery design to be retested in accordance with the UN Manual of Tests and Criteria.

The criteria by which a lithium battery is considered to be a new type and require retesting are found in § of the UN Manual of Tests and Criteria. One of the criteria that would require testing is when a cell or battery differs from the type tested by "a change that would lead to a failure of any of the tests." The type of change that might be considered to differ from a tested type, such that it might lead to failure of any of the test results, may include, but is not limited to: 1) a change in the material of the anode, cathode, the separator or electrolyte; 2) a change of protective devices, including hardware and software; 3) a change of safety design in cells or batteries, such as a venting valve; 4) a change in the number of component cells; or 5) a change in connecting mode of component cells. A manufacturer of lithium batteries should take these types of changes into account when determining whether or not a cell or battery is a new type and requires retesting.

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


Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries