Interpretation Response #15-0019 ([W.E Train Consulting] [Mr. Gene Sanders])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: W.E Train Consulting
Individual Name: Mr. Gene Sanders
Location State: FL Country: US
View the Interpretation Document
Response text:
July 31, 2015
Mr. Gene Sanders
Manager
W.E. Train Consulting
8710 W. Hillsborough Ave. #112
Tampa, FL 33615
Reference No. 15-0019
Dear Mr. Flaherty:
This is in response to your January 27, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the T.7 overcharge testing requirements for lithium batteries. You note that the United Nations Manual of Tests and Criteria, 5th Revised Edition in section 38.3.3(d) provides that “batteries not equipped with overcharge protection that are designed for use only in a battery assembly, which affords such protection, are not subject to the requirements of this test”. Your questions are paraphrased and answered as follows:
Q1. Must batteries that do not have overcharge protection, and are designed for use only in a battery assembly that does not have overcharge protection, pass test T.7 before being offered for transport as batteries?
A1. Yes. The exception from test T.7 applies only to batteries that do not have overcharge protection, and are designed for use only in a battery assembly which affords such protection. Batteries that do not have overcharge protection and are designed for use in a battery assembly that does not have overcharge protection must successfully pass test T.7 prior to being offered for transportation.
Q2. For a battery assembly that does not have overcharge protection and is itself assembled from batteries that do not have overcharge protection, would it be compliant with the UN Manual of Tests and Criteria and the HMR if only the battery assembly passed test T.7 even though the batteries in the battery assembly did not pass test T.7?
A2. Based on the information provided in your specific scenario, batteries without overcharge protection intended for installation in a battery assembly that also does not have overcharge protection, both the batteries and the battery assembly are subject to test T.7.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division