Interpretation Response #19-0110

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

Interpretation Response Details

Response Publish Date: 12/20/2019

Company Name: Aclara

Individual Name: Bill Laudolff

Location State: OH Country: US

View the Interpretation Document

Response text:

December 20, 2019

Bill Laudolff
Sr. Mechanical Engineer
Aclara
30400 Solon Road
Solon, OH  44136

Reference No. 19-0110

Dear Mr. Laudolff:

This letter is in response to your August 29, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery testing. Specifically, you seek clarification of the requirements to test certain battery configurations in accordance with the United Nations (UN) Manual of Tests and Criteria and confirmation that the battery configurations meet the requirements of § 173.185 of the HMR and may be offered for transport.

In your email, you provide the following conditions of the battery arrangements:

• Single cell batteries are permanently installed on a circuit board and then mounted into the final equipment, i.e. the battery is connected to the equipment with adequate protections and will not provide power to any other equipment.
   
• Each single cell lithium metal battery meets all the requirements and has been tested in accordance with the UN Manual of Tests and Criteria.

You further describe five battery configurations:

1. Multiple single cell batteries, each with less than 1 gram of lithium content, connected in parallel with a total of not more than 2 grams of lithium content per assembly.
2. Multiple single cell batteries, each with less than 1 gram of lithium content, connected in series with a total of not more than 2 grams of lithium content per assembly.
3. Multiple single cell batteries, each with more than 1 gram of lithium content, connected in parallel.
4. Multiple single cell batteries, each with more than 1 gram of lithium content, connected in series.
5. Any combination of series and parallel connections of single cell batteries.

You ask if each of the battery configurations described require additional testing in accordance with the UN Manual of Tests and Criteria.

The answer is yes. Section 173.185(a) of the HMR states that lithium batteries are subject to the tests in sub-section 38.3 of the UN Manual of Tests and Criteria, regardless of whether the cells used to construct the battery are of a tested type. In Part III, Sub-section 38.3 of the UN Manual of Tests and Criteria, a battery is defined as "two or more cells which are electrically connected together and fitted with devices necessary for use, for example, case, terminals, marking and protective devices." Based on the information provided in your email, it is the opinion of this Office that because the cells are electrically connected, whether in series or parallel, and fitted with devices necessary for use, such as a circuit board, this arrangement would meet the definition of a battery. Therefore, in accordance with § 173.185(a), each battery would need to meet the criteria in Part III, Sub-section 38.3 of the UN Manual of Tests and Criteria.

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

173.185, 173.185(a)

Regulation Sections