{"operation":"document","citation":"00-0026","title":"Mr. Richard L. Walters — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-04-20","effective_on":null,"summary":"00-0026 concerning 173.159.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0026.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0026.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0026","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000026.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington. D.C.\nResearch and\nSpecial Programs\nAdministration\nAPR 2 0 2000\nMr. Richard L.. Walters\nRef. No. 00-0026\nHSC Packaging Engineer\nP.O. Box 92919 Bldg.\nLos Angeles, CA 90009\nDear Mr. Walters:\nThis is in response to your letter dated January 18, 2000, and subsequent telephone conversation with\nMr. Eric Nelson of my staff regarding the classing of batteries you identified as nickel-hydrogen\nbatteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nYou stated that your battery uses aqueous potassium hydroxide as the electrolyte and is shipped with\nno free electrolyte that can spill, and contains no hydrogen. You also state that the battery is fully\ndischarged and shorted across both terminals when in transportation and passes the vibration and\npressure differential test requirements of § 173.159(d)(3). Based on the information you provided, it is\nthe opinion of this Office that your batteries in the above configuration are not regulated by the HMR\nprovided they are marked \"NONSPILLABLE\" or \"NONSPILLABLE BATTERY\" and are securely\npackaged.\nI hope this satisfies your request.\nSincerely,\nSuban Hills\nDelmer F. Billing\nChief, Standards Development\nOffice of Hazardous Materials Standards\n173.159\n000026\n\n<<<PAGE 2>>>\n\n. 7\nnelson\n8173.159\nR SP A Office of Hazardous\nMaterials Standards (DHM-10)\nHUGHES\nU.S. Department of Transportation\nSPACE & COMMUNICATIONS\n400 Seventh Street, S W.\n00-0026\nWashington, D C 20590 - 0001\n18 January, 2000\nRef. Request for written interpretive assistance 49 CFR § 107.14(b)\nPlease provide clarification of classification of nickel-hydrogen batteries and battery cells built by\nHughes Space & Communications Co.\nElectrolyte in nickel-hydrogen cells and batteries is aqueous potassium hydroxide, typically at 23\nto 34 percent by weight. It is a liquid at 55° C, and there is no excess electrolyte as the cells are\ndrained of any excess electrolyte as one of the final steps of the cell activation process.\nAlthough the electrolyte may account for 10 to 15 percent of a cell's weight, no electrolyte would\nbe free to flow from a cell or battery in the event of a crack or rupture. The electrolyte in the cell is\nmainly held in the pores of the positive electrodes and separators due to capillary action and\nsurface tension.\nCell (casing) construction is in accordance with MIL-STD-1522 (see attachment) titled \"Standard\nGeneral Requirements for Operation of Pressure Missile and Space Systems\", which exceeds the\nvibration test and pressure differential test requirements of 49 CFR § 173.159 (d)(3)\nCells and batteries are typically shipped and stored in a fully discharged and shorted condition, so\nshort-circuiting during transportation would not be an issue, and there would be no internal\npressure during transit.\nFully charged cells would contain hydrogen gas with internal pressure of up to 900 psig.\nCells or batteries are protected from short one or more of the following:\n(a) Cell design whereby cell terminals are physically located on opposite ends of the cell.\n(b) Battery design whereby all exposed cell terminals and power harnesses are covered with\nconformal coating and/or some form of electrical insulation.\n(c) Fitted caps for battery power connectors.\n(d) Packaging which protects the cells or batteries from damage, including from short circuit.\nsincerel\nRichard L. Walters\nHSC Packaging Engineer\nP.O. Box 92919 Bldg. S30 M/S T310\nLos Angeles, Ca. 90009\nHughes Space and Communications Company\n1(310) 4165690 fax 1(310) 4163130\nLos Angeles, CA 90009\nP.O. Box 92919","truncated":false,"body_characters":3601}