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Interpretation Response #16-0093 ([Broadcom Limited] [Mr. Richard Laudano])

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

Interpretation Response Details

Response Publish Date:

Company Name: Broadcom Limited

Individual Name: Mr. Richard Laudano

Location State: GA Country: US

View the Interpretation Document

Response text:

May 04, 2017

Mr. Richard Laudano
Commodity Engineer
Broadcom Limited
4165 Shackleford Road
Norcross, GA 30093

Reference No. 16-0093

Dear Mr. Laudano:

This letter is in response to your May 24, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to proper shipping names. Specifically, you ask for the appropriate proper shipping name for a Broadcom Cache Backup Unit (CBU) that contains a lithium ion cell electrically connected to a Printed Circuit Board Assembly (PCBA). You further state that the CBU provides power to RAID controller memory in the event of a power loss.

As specified in § 173.22 of the HMR, it is the shipper's responsibility to properly class and package a hazardous material. While this Office does not normally perform this function, we are able to provide guidance. Based on the information you provide in your emails and the requirements of the HMR, it is the opinion of this Office that the CBU in your scenario is most appropriately described as "UN3480, Lithium ion batteries." The introductory paragraph to § 173.185 of the HMR defines equipment as "...the device or apparatus for which the lithium cells or batteries will provide electrical power for its operation." According to your description, the CBU provides power to the RAID controller memory. As such, when shipped separate from the RAID controller memory, the CBU does not meet the definition for "UN3481, Lithium ion batteries contained in equipment."

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

 

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.22, 173.185

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
173.22 Shipper's responsibility