Interpretation Response #21-0080
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Ultra-Life Communications Systems
Individual Name: Tim Jennings
Location State: VA Country: US
View the Interpretation Document
Response text:
February 1, 2022
Tim Jennings
Ultra-Life Communications Systems
1457 Miller Store Road
Suite 106
Virginia Beach, VA 23455
Reference No. 21-0080
Dear Mr. Jennings:
This letter is in response to your July 23, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium ion batteries. You state that your company has developed a new product that houses a vibration isolated 6U half rack flight case with an uninterrupted power supply (UPS) and a drawer that holds a personal computer bolted to the rack. You also state that there is a lithium ion battery which supplies power to the electronics in the case—but only when the source of power (i.e., external AC power) is no longer available—and it continues to provide AC power until the lithium ion battery is fully drained. Finally, you state the power switch to operate the UPS is within the sealed case preventing any accidental activation of the product during transportation. You seek clarification to determine—for shipping purposes—if the lithium ion battery should be described as "UN3481, Lithium ion batteries contained in equipment including lithium ion polymer batteries, 9" or "UN3481, Lithium ion batteries packed with equipment including lithium ion polymer batteries, 9."
Based on the description of the product and the drawings you provided in your email, the lithium ion battery—as described—is considered a self-contained battery for the primary purpose of providing electrical power to separate equipment (i.e., the UPS) and therefore, should be described as "UN3480, Lithium ion batteries including lithium ion polymer batteries, 9." This is consistent with previously issued letters of interpretation (Ref. Nos. 16-0018 and 16-0125).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division