Interpretation Response #19-0092
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Total Compliance LLC
Individual Name: Chris Heminger
Location State: OH Country: US
View the Interpretation Document
Response text:
October 15, 2019
Chris Heminger, CPEA
Managing Partner
Total Compliance LLC
5859 Morganwood Square
Hilliard, OH 43026
Reference No. 19-0092
Dear Mr. Heminger:
This letter is in response to your June 26, 2019, letter and subsequent telephone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to proper shipping names.
In your letter, you state your client manufactures equipment powered by a removable, 16.2 Wh lithium ion battery power source. The removable power source consists of two, type A lithium ion batteries that are attached to a printed circuit board (PCB) and two safety circuits, all of which is completely enclosed within a solid plastic housing. You further state that the batteries themselves are intended to power equipment to which this device will ultimately be connected. Finally, you state your client believes that this material is best described as "UN3481, Lithium ion batteries contained in equipment, 9." You ask whether your client’s interpretation of the regulations is correct.
The answer is no. The batteries attached to a PCB do not power the PCB in the same manner as a battery powers an electric wheelchair or a laptop computer, but are instead used to supply electric power to separate equipment. Therefore, for purposes of the HMR, this device is essentially a battery and must be transported using a proper shipping name that most appropriately describes the battery type attached to the PCB.
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