Interpretation Response #17-0142
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Amigo Mobility International, Inc.
Individual Name: Al Bussinger
Location State: MI Country: US
View the Interpretation Document
Response text:
June 29, 2018
Al Bussinger
Amigo Mobility International, Inc.
6693 Dixie Highway
Bridgeport, MI 48722
Reference No. 17-0142
Dear Mr. Bussinger:
This letter is in response to your December 26, 2017, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium cells and batteries. You provide a description and schematics of a proposed lithium ion battery pack design in which two batteries are contained in a single case, but the two batteries are not electrically connected at any point during transportation and can only be electrically connected when installed in equipment. Specifically, you ask if the proposed lithium ion battery pack design is considered a single battery or multiple batteries in a single case.
Based on the information described in your email and the attachments provided, it is the opinion of this Office that your lithium ion battery pack design would constitute individual lithium ion batteries in a single case, provided the batteries remain electrically isolated in transportation.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division