Interpretation Response #23-0045
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: L-H Battery Company, Inc.
Individual Name: Mr. Rick Riggle
Location State: OH Country: US
View the Interpretation Document
Response text:
January 30, 2024
Mr. Rick Riggle
Chief Operating Officer
L-H Battery Company, Inc.
8500 Bluegrass Blvd. NW
Jeffersonville, OH 43128
Reference No. 23-0045
Dear Mr. Riggle:
This letter is in response to your April 17, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium ion batteries transported by highway. In your letter, you describe a lithium ion battery module that weighs more than 12 kg with an aluminum casing. As depicted in the photographs you provided, the aluminum casing has a series of large ventilation slots on the top for heat dissipation and a layer of poly carbonate that separates the cells from the casing and protects the cells from direct exposure. You ask whether the lithium ion battery module configuration with the large ventilation slots satisfies the “strong-impact-resistant outer casing” requirement as specified in § 173.185(b)(5).
Provided that (1) the aluminum casing with large ventilation slots—as depicted in your photographs—is strong and impact-resistant, (2) the lithium ion batteries are secured to prevent inadvertent shifting, (3) the terminals do not support the weight of other superimposed elements, and (4) the lithium ion battery module configuration is further packaged in strong outer packagings, protective enclosures, or on pallets or other handling devices, it is the opinion of this Office that the specific packaging configuration you describe and provided photographs for is acceptable for highway transportation in accordance with § 173.185(b)(5).
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(b)(5)
Regulation Sections
| Section | Subject |
|---|---|
| 173.185 | Lithium cells and batteries |