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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #98-0383 ([Radian International] [Mr. Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: Radian International

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

MAR 31, 1999


Mr. Andrew N. Romach                    Ref No. 98-0383
Corporate Regulatory Manager
Radian International
Post Office Box 13000
Research Triangle Park, NC 27709

Dear Mr. Romach:

This is in response to your letter requesting clarification relating to lithium batteries under the provisions of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Your questions have been paraphrased and answered as follows:

Ql. In the United Nation's (LJN) Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, the word "battery" means two or more cells which are electrically connected together by a permanent means.  Is this definition applicable to the provisions specified in § 173.185?

Al.        Yes, the UN definition of a "battery" is applicable to the lithium battery provisions specified in § 173.185.

Q2. If the Department of Transportation does not recognize this definition, how does DOT define the word "battery?"

A2. See above response.

Q3. Does the term "permanent means" include a soldered or welded connection, or a connection screwed together?

A3. The term "permanent means" could include a soldered or welded connection, but not a connection screwed together.

Q4. Would examples of a non-permanent means include metal clips or holders where the batteries could be removed easily?

A4. Yes, metal clips or holders are considered a non-permanent means of attachment.

Q5. Does the enclosed diagram constitute one battery or many batteries, assuming the individual cells are clipped into battery holders so the cell can be removed readily?

A5. Based on your diagram, you have one battery containing 16 cells.

I hope this answers your inquiry.  If you need additional assistance, do not hesitate to contact us.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries