Interpretation Response #16-0015 ([Consultant to Bosh Global Services] [Mr. Fred Marks])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Consultant to Bosh Global Services
Individual Name: Mr. Fred Marks
Location State: MD Country: US
View the Interpretation Document
Response text:
June 27, 2016
Mr. Fred Marks
Consultant to Bosh Global Services
727 Regent Ct.
Gaithersburg, MD 20878
Ref. No.: 16-0015
Dear Mr. Marks
This responds to your January 19, 2016 e-mail and subsequent conversations with a member of my staff, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask several questions concerning the applicability of the T.7 test found in the United Nations Manual of Tests and Criteria, 5th Revised Edition (UN Manual of Tests and Criteria), including Amendments 1 and 2, to your particular battery configuration. You state that your battery assembly consists of six batteries each containing four lithium ion cells and a Watt-hour rating (Wh) of 98 Wh. You note that your battery assembly has a pack protection cap (PPC) containing a charge protection module (PCM) that ensures the battery never has an overvoltage applied to it. This PPC is only removed during the use of the battery and remains in place during charge, storage, and transport. You further note that charging of the battery is only possible with the PPC snapped to the battery as a part of the battery assembly. You state it is not possible to charge the battery without the PPC in place without deliberate damage to the battery assembly to permit access to internal terminals and nodes. Your questions are paraphrased and answered as follows:
Q1. Are batteries that do not have overcharge protection that are designed for use only as a component in a battery assembly that provides overcharge protection afforded the exception from test T.7 in the UN Manual of Tests and Criteria in section 38.3.3(d)?
A1. The answer to your question is yes. Section 38.3.3(d) clearly states 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 test T.7.
Q2. Do batteries that are designed for use only as a component of a battery assembly equipped with a removable PPC providing overcharge protection that is only removed during use and remains in place during charge, storage, and transport need to pass the T.7 test of the UN Manual of Tests and Criteria?
A2. The UN Manual of Tests and Criteria do not delineate between permanently installed overcharge protection and removable overcharge protection. As noted in the information you have provided, it is only possible to charge the battery assembly without the “PPC” in place by means of deliberate damage to the battery assembly to permit access to internal terminals and nodes. In the absence of such deliberate damage to the battery assembly the “PPC” will provide overcharge protection. It is the opinion of this Office, based on the information you have provided, the “PPC” component of your battery assembly provides overcharge protection meeting the requirements in 38.3.3(d) and consequentially batteries designed only for use in such battery assemblies equipped with your “PPC” overcharge protection are not required to pass the T.7 test in the UN Manual of Tests and Criteria. To be clear, the PPC would need to be installed in the battery assembly while in transportation.
Q3. Is the battery assembly that includes the PPC required to undergo test T.7 as an assembly?
A3. The answer to your question is yes. Section 38.3.3(f) of the UN Manual of Tests and Criteria requires a lithium ion battery assembly, with a Watt-hour rating of not more than 6,200 Wh, that is assembled from batteries that have passed all applicable tests, to test one battery assembly in a fully charged state under tests T.3, T.4 and T.5, and, in addition, test T.7 in the case of a rechargeable battery assembly. For a rechargeable battery assembly, the assembly shall have been cycled at least 25 cycles. For a lithium ion battery, with a Watt-hour rating of more than 6,200 Wh, the battery assembly does not need to be tested if it is equipped with a system capable of monitoring the battery assembly and preventing short circuits, or over discharge between the batteries in the assembly and any overheat or overcharge of the battery assembly.
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
38.3.3(d)