{"operation":"document","citation":"05-0193","title":"MGA Research Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-07-11","effective_on":null,"summary":"05-0193 response to MGA Research Corporation concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0193.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0193.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0193","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050193.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh Street, S.W\nWashington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAdministration\nJUL 11 2006\nMr. Anthony J. Angello\nRef No.: 05-0193\nQuality Manger\nTechnical Services Labratory\nMechanical Engineer\nMGA Research Corporation\n12790 Main Road\nAkron, NY 14001\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for testing of lithium\nThis is in response to your letter dated June 9, 2005, concerning requirements under the\nion batteries. The specific requirements you address are contained in Section 38.3 of the\nUnited Nations Manual of Tests and Criteria (UN Manual) and are implemented through\nthe provisions of 49 CFR 173.185. Your questions are paraphrased and answered below:\nQ1. If one cell or battery of a lot fails a test, should an entire lot be retested, or can a\nreplacement be used in its place?\nA1. In accordance with Paragraph 38.3.2.1, if a lithium cell or battery type does not meet\nne or more of the test requirements, steps shall be taken to correct the deficiericy o\nleficiencies that caused the failure before such cell or battery type is retested. The cell\nand batteries must be subjected to all tests.\nQ2. If a cell or battery fails one test, should the model be retested through all tests, or\nonly the test it failed?\nTests T.1 - T.8. Tests T.1 - T.5 must be conducted in sequence on the same cell or\nA2. In accordance with Paragraph 38.3.4, each cell and battery type must be subjected to\nand Tests T.6 and T.8 should be conducted using not otherwise tested cells or batteries.\nbattery, T.7 may be done using undamaged batteries previously used in Tests T.1 - T.5,\nIt a cell or battery fails a test steps shall be taken to correct the deficiency or deficiencies\nand the battery must be subjected to Tests T.1 - T.8.\nQ3. What is the definition of the phrase \"solid matter\" and term \"penetrate\" as used in the\ndefinition \"disassembly\" in Paragraph 38.3.2.2 of the UN Manual?\natoms are arranged in a three-dimensional lattice, periodic in three independent\nA3. Solid matter is defined as a crystalline material, that is, one in which the constituent\ndirections. Penetrate is defined as pass into or through, often by overcoming resistance.\nThe term disassembly, as provided in 38.3.2.2, can be clarified to mean ejectior of solid\nparticles at a force that causes them to tear through or pass through a wire mesh screen\nplaced 25 cm away from the cell or battery.\n173.185\n050193\n\n<<<PAGE 2>>>\n\nQ4. Would it be more appropriate to use lead shot or a solid steel bar for impact testing?\nIf a steel bar is used, is any type of dampening material such as rubber, allowed in\nbetween the bar and the impact mass?\nA4. Paragraph 38.3.4.6.2 of the UN Manual requires a 9.1 kg mass to be dropped on the\n9.1 kg mass\" to indicate that the material must be a single mass such as the steel bar.\nsample from a height of 61 = 2.5 cm. In our opinion, the UN Manual uses the phrase \"a\nQ5. Can a constant current source be substituted for the 12V D.C. power supply for the\nForced Discharge test in Paragraph 38.3.4.8.2?\nA5. Yes, provided each cell is force discharged for the time interval (in hours) equal to its\nrated capacity divided by the initial test current (in Ampere).\ncurrent can be maintained for a period of 24-hours regardless of the charge voltage?\nQ6. Has the Overcharge testing in Paragraph 38.3.4.7 been met if the required overcharge\nA6. To fulfill the test procedure and requirements, charge voltage must be as specified in\n38.3.4.7.2(a) or (b), as applicable. In addition, there must be no disassembly or fire of the\nrechargeable battery within seven days of the test.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nFrom: Anthony Agnello [mailto:anthony.agnello@mgaresearch.com]\n-----Original Message----\nSupko\nSent: Thursday, June 09, 2005 1:08 PM\nSubject: Questions regarding UN ST-SG-AC10-27a2e\nTo: Shane.Kelley@dot.gov; infoentr@dot.gov\n$173.185\nBatleries\nPlease\nforeward to Charles Key.\n85-0 1 93\nAs we spoke\nof Dangerous Goods, Manual of Tests\nof, I have several questions regarding the UN Recommendations on the Transport\nyou have any questions,\nor if you need any clarification, please do not hesitate to\nand Criteria,\nRev. 4, Para 38.3 Lithium Batteries.\ncontact me at (716) 542-5515.\ncells/batteries be retested, or\nIf one cell/battery of\ncan a replacement\nfails a test,\ne used in its place? (Refer to Par\nshould an entire lot o\nthrough all tests,\nIf cells/batteries fails one test,\nor only the test it failed?\n3.\n(Refer to Para 38.3.2.1)\na.\nDisassembly)\nof a wet/moist dirt, baking flour/dust, oil, grease, or is it strictly metal components.\nSolid Matter - Is solid matter an internal material the consistency\nscreen, or tear through?\nb.\nPenetrate - Does penetrate mean to pass through the wire mesh\nto use a bag of lead shot\nFor impact testing,\nfor a 9.1 kg mass?\n(Refer to Para 38.3.4.6) would it be appropriate\ncell and bar to disperse the force of the drop to the cell, bar, and table.\nA bag of lead shot would conform around the\ncover the cell and prevent any disassembly.\nWould it be appropriate to use a solid steel\nIt would also\nmass that would directly impact the bar and transmit the entire force of the drop to only\nmaterial, such as rubber, allowed in-between the bar and the impact masis?\nThe bar would then transmit the force to the cell. Is any type of dampening\nconstant current source be substituted for the 12 VDC power supply?\nFor Forced Discharge testing,\n(Refer to Para 38.3.4.8) can a\nrequired overcharge current can be maintained for a period of 24-hours regardless of the\nRegarding Overcharge Testing\n(Refer to Para 38.3.4.7).\ncharge voltage, has the requirement been met?\nRegards,\nAnthony\nQuality Manager\nAnthony J. Agnello\nTechnical Services Laboratory\nMechanical (Test) Engineer\n12790 Main Road\nMGA Research Corporation\nPhone: (716) 542-5515\nAkron, NY 14001\nFax: (716) 542-4437\nWebsite: http://www.TechnicalServicesLab.com/\nEmail: anthony.agnello@mgaresearch.com\nThe documents accompanying this transmission\nConfidentiality Note\nCorporation that may be confidential and/or proprietary. If you have received this in\ncontain information from MGA Research\nerror please notify immediately. Thank you","truncated":false,"body_characters":6368}