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Interpretation Response #99-0070 ([Delphi Automotive Systems] [Mr. Dave McCullough])

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

Interpretation Response Details

Response Publish Date:

Company Name: Delphi Automotive Systems

Individual Name: Mr. Dave McCullough

Location State: IN Country: US

View the Interpretation Document

Response text:

APR 13, 1999


Mr. Dave McCullough                        Ref No: 99-0070
Delphi Hazardous Materials Coordinator
Delphi Automotive Systems
P.O. Box 502650
Indianapolis, Indiana 46256

Dear Mr. McCullough:

This is in response to your letter of February 25, 1999, requesting clarification on the shipment of lithium ion batteries under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  Specifically you ask for clarification of the requirements of § 173.185 as they relate to lithium ion batteries.  You state that the UN Recommendations for the Transport of Dangerous Goods has adopted a formula for determining equivalent lithium content for lithium ion batteries in Section 3 which reads as follows:

Lithium content means the mass of lithium in the anode of a lithium metal or lithium alloy cell, which for a primary cell is measured when the ce1l is in an undischarged state and for a rechargeable cell is measured when the cell is fully,charged, except in the case. of a lithium-ion cell the lithium content is measured in terms of equivalent lithium content, which in grains is calculated to be 0.3 times the rated Capacity in ampere hours.

You ask if this formula may be used for determining the size of lithium ion batteries under the provisions of § 173.185. The answer is yes.  This method for determining the equivalent lithium content for lithium ion batteries will be proposed for adoption into the HMR in a future rulemaking action.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries