House of Batteries — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Materials Safety Administratior Pipeline and Hazardous AUG 22 2006 Mr. Brion Munsey House of Batteries Western Regional Sales Manager Ref. No. 06-0079 10910 Talbert Avenue Fountain Valley, CA 92708 Dear Mr. Munsey: This is in response to your letter and subsequent conversation with Mr. Darral Reierford concerning the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for excepted shipments of primary lithium cells and batteries. Specifically, you ask whether your primary lithium cells assembled into three-cell stacks, which you refer to as "CR2032 primary lithium coin cells" with a lithium content of 0.062g of lithium metal, are subject to the requirements in the UN Manual of Tests and Criteria for lithium batteries. According to your letter the cells, which individually conform to the UN testing requirements, are stacked one on top of the other and held together by PVC heat shrink tubing and the cells are not permanently connected together. Based on the diagram and information provided, it appears that the "three cell stack that are in direct contact with one another meets the definition for a "battery" as described by the configuration" of your "CR2032 primary lithium coin cells" containing 0.062g of lithium metal UN and applicable to the lithium battery provisions in § 173.185 of the HMR. In the United Fourth Revised Edition the word "battery" means one or more cells that are electrically Nation's Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, connected together by a "permanent means," including case, terminals, and markings. this office. I hope this information is helpful. If you have further questions, please do not hesitate to contact Sincerely, John A Gale Chief, Standards Development Office of Hazardous Materials Standards 173.185 060079#

Page 2MAR-30-2006 13:52 HOUSEOFBATTERIES 7149627644 P.01 Relentore 3173.185 Lith um Batteries 06-0079 10910 Talbert Avenue, Fountain Valley, CA 92708 714-962-7600 1-800-432-3385 FAX: 714-962-7644 Batteries® www.houseofbatteries.com Batteries and Assemblies for Every Electronic Application March 30, 2005 • Mr. Edward Mazzullo Director of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration 400 7* Street, SW U.S. Department of Transportation Washington, DC 20590 Re: UN Testing Requirement for Lithiur Batteries Dear Mr. Mazzullo: I am writing to confirm our understanding of the UN lithium battery testing requirements as they apply to one of our products. House of Batteries is a small business, less than 100 employees, and we assemble a variety of single and multi-cell lithium, lithium ion, and lithium polymer battery packs. One of our customers has requested The Croz th used it a see sain compant of he 2 sium primary requirements, and each cell has only 0.062g of lithium metal. CR2032 cells also have a solid cathode not liquid. cells are not permanently welded together. The cells in this configuration will be shipped The cells will be stacked one on top of the other and held together by PVC heat shrink tubing. The domestically as well as internationally.#

Page 3MAR-30-2006 13:52 HOUSEOFBATTERIES 71.49627644 P.02 10910 Talbert Avenue, Fountain Valley, CA 92708 714-962-7600 1-800-432-3385 FAX: 714-962-7644 www.houseofbatteries.com Batteries® Batteries and Assemblies for Every Electronic Application to believe that this cell configuration does not require UN testing. The three-cell configuration does Our understanding of the lithium battery testing requirements for lithium cells and batteries leads us not meet the definition of a "battery" (one or more cells which are electrically connected together permanently connected together but simply placed inside a PVC sleeve to facilitate shipping and ease by permanent means, including case, terminals, and markings") because the cells are rot of installation. The final user has the option of utilizing the cells individually in various applications. configuration is not subject to the UN testing requirements for lithium batteries. Therefore, based on the information we have provided, please confirm that the three-cell Thank you for your assistance. Regards, Brion Munsey Western Regional Sales Manager TOTAL P.Ø2#