{"operation":"document","citation":"08-0028","title":"Raytheon Missile Systems — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-07-09","effective_on":null,"summary":"08-0028 response to Raytheon Missile Systems concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0028.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0028.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0028","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080028.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Steve Jacob\nRaytheon Missile Systems\n11651 N. Via De La Verbenita\nOro Valley, AZ 85737\nRef. No. 08-0028\nDear Mr. Jacob:\nThis responds to your January 24,2008 request for clarification on a container designed to\ntransport a lithium battery under the Hazardous Materials Regulations (HMR; 49 CFR Parts\n171-180).\nAccording to your request, you have designed a container to ship a lithium ion battery to be\nused by the military. The container will contain a total of 18 batteries connected in three\nbanks. Each of the 18 batteries consists of 25 cells in a plastic, sealed, waterproof enclosure\nwith a vent. Each bank of six batteries is tightly assembled and enclosed in a strong\naluminum box; the three boxes are assembled together to make a single unit. The outside\ncontainer is waterproof and includes a charging device connected to the large battery\nassembly. The container includes mechanisms to protect the battery assembly from shock\nand vibration to prevent short circuits and reverse charging. The total weight of the battery\nassembly is 26 kg; the total weight of the assembly with aluminum enclosures is 41 kg. The\nbattery assembly contains a total of 0.3 15 kg of lithium.\nYour questions are paraphrased and answered as follows:\nQ1. Does this configuration conform to the HMR for transportation by highway?\nWhat test requirements apply to the container? Is a liner required?\nAl. The battery assembly must conform to the requirements in 173.1 85 of the HMR. Thus,\namong other requirements, the battery assembly must be tested in accordance with the UN\nManual of Tests and Criteria and must be packaged in combinati-on packagings conforming\nto the requirements of Subparts L and M of Part 178 at the Packing Group I1 performance\nlevel. A liner is not required if the container is waterproof. Packaging test requirements and\npass/fail criteria are in Subpart M of part 178.\n\n<<>>\n\nQ2. May the battery be connected and charging during transportation?\nA2. No. The terminals must be protected from damage and short circuits. Batteries\nconnected and charging during transportation may pose a short circuit hazard.\nIf you cannot comply with the 5 173.185 requirements, you must apply for an Approval from\nthe Office of Special Permits and Approvals. Procedures for applying for an Approval are in\nSubpart H of Part 107 in the HMR.\nI hope this answers your inquiry.\nSincerely,\nSusan Gorsky u\nRegulations officer\nOffice of Hazardous Materials Standards\n\n<<>>\n\nPage 1 of 2\nDrakeford, Carolyn \nFrom: INFOCNTR \nSent: Thursday, January 24, 2008 4:51 PM\nTo: Drakeford, Carolyn \nSubject: FW: Interpretation on 173.185\nFrom: Steven D Jacob [mailto:SteveJacob@raytheon.com]\nSent: Thursday, January 24,2008 4:30 PM\nTo: INFOCNTR \nSubject: Interpretation on 173.185\nI spoke to Jenny and she told me that if I wanted a written letter of interpretation that I needed to ask for one,\nplease send one.\nWe are designing a container to ship a lithium ion battery that will be used by the Army. The battery will be placed\nin a container, the battery has the following characteristics; it has 18 batteries within it which are BB2590\n(standard Army battery) that are connected in 3 banks (6 batteries per bank, 3 x 6 = 18). Each bank of 6 batteries\nis tightly assembled and enclosed in a strong aluminum box then the 3 boxes are assembled together to make a\nsingle unit of 18 batteries. Each smaller battery (BB2590) has 24 cells in it and has a plastic sealed waterproof\nenclosure with a vent. Each cell is of the 18650 lithium ion kind. The total weight of all 18 batteries is 26 kg (57 Ib);\nthe total weight of the assembly with the aluminum enclosures is 41 kg (90 Ib). The total battery has 0.315 kg of\nlithium (0.7 Ib)\nThe container is made waterproof and is also a charging device; it has a connector that connects to the large\nbattery assembly. The container also has mechanical shock isolation within it to protect the battery from damage\ndue to shock and vibration. The output of the battery is wired to a connector that is mounted on the outside panel\nof the container, there is a protective plastic cover over the connector that is captive and used to prevent the\nconnector from shorting. There is also a protection diode in series with the connector to the battery to prevent\nreverse charging.\nMy questions are as follows:\n1) Can I meet the requirements of CFR 49 with the current configuration so that the battery and container may be\ntransported on roadways?\n2) Can the battery while it is in the container be connected and charging wh~le beiqg transported on roadways?\n3) Do I have to conduct some sort of drop test or POP test to the container? If yes then does the battery need to\nbe in it while it is being tested? What is a pass and what is a failure?\n4) Do I need liner in the container? (The individual batteries are already sealed in a plastic enclosure and vented)\n5) Can you identify anything that I am missing? My purpose is to be able to transport on roadways the battery in\nthe container.\nPlease send a written interpretation, it may be emailed to me at steve~acob@raytheon.com or sent to my home\naddress: 11651 N. Via De La Verbenita, Oro Valley, AZ 85737. 1 am giving you my home address because oltr\ninteroff~ce mail is very slow.\nThank you\nSteve Jacob\n\n<<>>\n\nPrincipal Electrical Engineer\nRaytheon\n520.794.21 32\nSteve Jacob\nPrincipal Electrical Engineer\nRaytheon Missile Systems\n520.794.21 32\nSteveJacob@Raytheon.com\nPage 2 of 2","truncated":false,"body_characters":5648}