Interpretation Response #18-0065
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Wiley Rein LLP
Individual Name: Susan Bernard
Location State: DC Country: US
View the Interpretation Document
Response text:
October 11, 2018
Susan Bernard
Wiley Rein LLP
1776 K Street NW
Washington, DC 20006
Reference No. 18-0065
Dear Ms. Bernard:
This letter is in response to your client's April 17, 2018, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium ion battery packs. Your client describes the lithium ion battery pack as follows:
- The battery pack is designed to provide power to various measurement and radio equipment.
- The design consists of two individual batteries with cells in series and parallel contained in a single plastic housing.
- The battery pack includes a printed circuit board assembly (PCBA) enclosed in the plastic housing.
- Each lithium battery is separately wired to the PCBA.
- The PCBA provides independent protection circuitry for each individual battery.
- These batteries have been tested in accordance with the United Nations (UN) 38.3 lithium battery test in accordance with the HMR.
Your client asks if the battery pack as described and illustrated in his letter is considered two individual batteries for purposes of the HMR.
Based on the proprietary memorandum you provided describing the configuration and the associated schematics, it is the opinion of this Office that your client's rechargeable battery pack is comprised of two batteries provided they are electrically isolated from each other.
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 Branch
Standards and Rulemaking Division