Interpretation Response #16-0155 ([Baker Hughes] [Mr. Keegan Ritchie])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Baker Hughes
Individual Name: Mr. Keegan Ritchie
Country: CA
View the Interpretation Document
Response text:
April 06, 2017
Mr. Keegan Ritchie
RDD Engineering Technologist
Baker Hughes - Pipeline Inspection
4839 90th Avenue S.E.
Calgary, Alberta T2C2S8
Canada
Reference No. 16-0155
Dear Mr. Ritchie:
This letter is in response to your September 22, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to testing requirements for a lithium metal battery. Specifically, you ask if you can substitute the component cells in a lithium battery from one brand to another without having to retest the battery in accordance with Part III Sub-Section 38.3 of the United Nations (UN) Manual of Tests and Criteria.
According to your letter, you plan to change the component cells in your in-house assembled battery pack from one brand to another. Both the existing cells and the new cells are the same chemistry (Lithium Sulfuryl Chloride), the same shape and dimensions, and of a type proven to meet the tests in Sub-Section 38.3 of the UN Manual of Tests and Criteria. However, the lithium weight of the new cells decreases from 10.2 grams (existing cells) to 9.6 grams (new cells).
The provisions in Section 38.3.2.2 are intended to provide a tolerance for minor differences that may develop during the manufacture of otherwise identical cells or batteries. Using only the information you provide in your letter, this Office cannot make a determination that the new component cells are identical to the existing cells, as there are various features inherent to the new cells (such as diodes and a specific electrolyte) that may or may not be present in the existing cells.
Section 38.3.2.2 of the UN Manual of Tests and Criteria states for primary cells and batteries a change of 0.1 grams or 20% by mass—whichever is greater—to the cathode, the anode, or the electrolyte or any change to a lithium battery that would lead to failure of any of the tests prescribed in this section must be considered a new type and subjected to the required tests. Section 38.3.2.2 (c) also describes the types of changes that may be considered sufficiently different from a tested type so that it might lead to a failure of a lithium battery test result. These changes include but are not limited to the following:
- A change in the material of the anode, the cathode, the separator, or the electrolyte;
- A change of protective devices, including hardware and software;
- A change of safety design in cells or batteries, such as a venting valve;
- A change in the number of component cells; and
- A change in connecting mode of component cells.
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
38.3, 38.3.2.2, 38.3.2.2 (c)