MGA Research Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration JUL 11 2006 Mr. Anthony J. Angello Ref No.: 05-0193 Quality Manger Technical Services Labratory Mechanical Engineer MGA Research Corporation 12790 Main Road Akron, NY 14001 Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for testing of lithium This is in response to your letter dated June 9, 2005, concerning requirements under the ion batteries. The specific requirements you address are contained in Section 38.3 of the United Nations Manual of Tests and Criteria (UN Manual) and are implemented through the provisions of 49 CFR 173.185. Your questions are paraphrased and answered below: Q1. If one cell or battery of a lot fails a test, should an entire lot be retested, or can a replacement be used in its place? A1. In accordance with Paragraph 38.3.2.1, if a lithium cell or battery type does not meet ne or more of the test requirements, steps shall be taken to correct the deficiericy o leficiencies that caused the failure before such cell or battery type is retested. The cell and batteries must be subjected to all tests. Q2. If a cell or battery fails one test, should the model be retested through all tests, or only the test it failed? Tests T.1 - T.8. Tests T.1 - T.5 must be conducted in sequence on the same cell or A2. In accordance with Paragraph 38.3.4, each cell and battery type must be subjected to and Tests T.6 and T.8 should be conducted using not otherwise tested cells or batteries. battery, T.7 may be done using undamaged batteries previously used in Tests T.1 - T.5, It a cell or battery fails a test steps shall be taken to correct the deficiency or deficiencies and the battery must be subjected to Tests T.1 - T.8. Q3. What is the definition of the phrase "solid matter" and term "penetrate" as used in the definition "disassembly" in Paragraph 38.3.2.2 of the UN Manual? atoms are arranged in a three-dimensional lattice, periodic in three independent A3. Solid matter is defined as a crystalline material, that is, one in which the constituent directions. Penetrate is defined as pass into or through, often by overcoming resistance. The term disassembly, as provided in 38.3.2.2, can be clarified to mean ejectior of solid particles at a force that causes them to tear through or pass through a wire mesh screen placed 25 cm away from the cell or battery. 173.185 050193#

Page 2Q4. Would it be more appropriate to use lead shot or a solid steel bar for impact testing? If a steel bar is used, is any type of dampening material such as rubber, allowed in between the bar and the impact mass? A4. Paragraph 38.3.4.6.2 of the UN Manual requires a 9.1 kg mass to be dropped on the 9.1 kg mass" to indicate that the material must be a single mass such as the steel bar. sample from a height of 61 = 2.5 cm. In our opinion, the UN Manual uses the phrase "a Q5. Can a constant current source be substituted for the 12V D.C. power supply for the Forced Discharge test in Paragraph 38.3.4.8.2? A5. Yes, provided each cell is force discharged for the time interval (in hours) equal to its rated capacity divided by the initial test current (in Ampere). current can be maintained for a period of 24-hours regardless of the charge voltage? Q6. Has the Overcharge testing in Paragraph 38.3.4.7 been met if the required overcharge A6. To fulfill the test procedure and requirements, charge voltage must be as specified in 38.3.4.7.2(a) or (b), as applicable. In addition, there must be no disassembly or fire of the rechargeable battery within seven days of the test. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards#

Page 3From: Anthony Agnello [mailto:anthony.agnello@mgaresearch.com] -----Original Message---- Supko Sent: Thursday, June 09, 2005 1:08 PM Subject: Questions regarding UN ST-SG-AC10-27a2e To: Shane.Kelley@dot.gov; infoentr@dot.gov $173.185 Batleries Please foreward to Charles Key. 85-0 1 93 As we spoke of Dangerous Goods, Manual of Tests of, I have several questions regarding the UN Recommendations on the Transport you have any questions, or if you need any clarification, please do not hesitate to and Criteria, Rev. 4, Para 38.3 Lithium Batteries. contact me at (716) 542-5515. cells/batteries be retested, or If one cell/battery of can a replacement fails a test, e used in its place? (Refer to Par should an entire lot o through all tests, If cells/batteries fails one test, or only the test it failed? 3. (Refer to Para 38.3.2.1) a. Disassembly) of a wet/moist dirt, baking flour/dust, oil, grease, or is it strictly metal components. Solid Matter - Is solid matter an internal material the consistency screen, or tear through? b. Penetrate - Does penetrate mean to pass through the wire mesh to use a bag of lead shot For impact testing, for a 9.1 kg mass? (Refer to Para 38.3.4.6) would it be appropriate cell and bar to disperse the force of the drop to the cell, bar, and table. A bag of lead shot would conform around the cover the cell and prevent any disassembly. Would it be appropriate to use a solid steel It would also mass that would directly impact the bar and transmit the entire force of the drop to only material, such as rubber, allowed in-between the bar and the impact masis? The bar would then transmit the force to the cell. Is any type of dampening constant current source be substituted for the 12 VDC power supply? For Forced Discharge testing, (Refer to Para 38.3.4.8) can a required overcharge current can be maintained for a period of 24-hours regardless of the Regarding Overcharge Testing (Refer to Para 38.3.4.7). charge voltage, has the requirement been met? Regards, Anthony Quality Manager Anthony J. Agnello Technical Services Laboratory Mechanical (Test) Engineer 12790 Main Road MGA Research Corporation Phone: (716) 542-5515 Akron, NY 14001 Fax: (716) 542-4437 Website: http://www.TechnicalServicesLab.com/ Email: anthony.agnello@mgaresearch.com The documents accompanying this transmission Confidentiality Note Corporation that may be confidential and/or proprietary. If you have received this in contain information from MGA Research error please notify immediately. Thank you#