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Interpretation Response #23-0088

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

Interpretation Response Details

Response Publish Date:

Company Name: Wabtec Corporation

Individual Name: Vincent M. Melillo

Location State: PA Country: US

View the Interpretation Document

Response text:

December 12, 2023

Vincent M. Melillo
Wabtec Corporation
2901 East Lake Road
Erie, PA  16531

Reference No. 23-0088

Dear Mr. Melillo:

This letter is in response to your October 5, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries. You provide schematics for a lithium ion battery pack design that weighs approximately 1600 lbs, with a completely enclosed fiberglass-resin composite casing comprised of "end cap" housings and "covers" with a nominal thicknesses of 0.20 inch and 0.13 inch respectively. The end caps are mounted and sealed to the ends of the covers at each end with an aluminum chill plate and the covers are mounted and sealed against the top and bottom faces of the aluminum chill plate. When fully assembled, the battery pack is sealed. You ask for confirmation that the battery pack design described above, and illustrated in the schematics you provided, would meet the requirement in § 173.185(b)(5) to have a "strong, impact-resistant outer casing."

Based on the information in the schematics you provided, it is the opinion of this Office that the battery pack design meets the performance standard of a strong, impact-resistant outer casing as specified in § 173.185(b)(5).

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries