Interpretation Response #14-0152 ([Space Information Laboratories] [Mr. Nick Pelster])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Space Information Laboratories
Individual Name: Mr. Nick Pelster
Location State: CA Country: US
View the Interpretation Document
Response text:
November 25, 2014
Mr. Nick Pelster
Program Manager
Space Information Laboratories
2260 S. Meredith Lane
Santa Maria, CA 93455
Ref. No.: 14-0152
Dear Mr. Pelster:
This responds to your July 31, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the testing of rechargeable lithium cells and batteries. On behalf of Space Information Laboratories (SIL), in your letter you state that SIL has four battery units undergoing United Nations (UN) Manual of Tests and Criteria testing. The SIL battery unit consists of two cell packs and a printed circuit board assembly (PCBA) which is enclosed in an aluminum housing. You state that each cell pack consists of eight lithium-ion pouch cells and that each cell pack is separately wired to the PCBA. You state that the PCBA provides independent protection circuitry for each cell pack. You provided a proprietary memorandum that described the configuration in more detail along with associated schematics. You note that according to the definitions in 38.3.2.2 of the UN Manual of Tests and Criteria, your units are considered small batteries because the gross weight is less than 12 kg. You further note that according to 38.3.3(b)(ii) and (b)(iii) of the UN Manual of Tests and Criteria, when testing rechargeable cells and batteries under tests 1 to 5, the required testing is for eight small batteries; four of which are charge cycled 50 times and four of which are at 1st charge cycled. You ask whether your 20 Ah rechargeable battery unit would be considered two batteries (or one battery) for the purpose of meeting the UN Manual of Tests and Criteria requirements.
Based on the proprietary memorandum you provided describing the configuration along with the associated schematics, it is the opinion of this Office that your 20 Ah rechargeable battery unit is comprised of two batteries provided they are electrically isolated from each other.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
38.3.2.2, 38.3.3(b)(ii)(iii)