{"operation":"document","citation":"08-0051","title":"Phillips Medical Systems — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-06-11","effective_on":null,"summary":"08-0051 response to Phillips Medical Systems concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0051.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0051.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0051","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080051.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJUN 1 1 2008\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Alan Greenstein\nPhillips Medical Systems\n2301 5th Ave., Suite 200\nSeattle, WA 98 12 1\nRef. No.: 08-0051\nDear Mr. Greenstein:\nThis is in response to your February 29, 2008 letter concerning the applicability of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80) to two configurations of\nlithium metal cells mounted into casing. Specifically you ask if your configurations of\nlithium metal cells constitute a lithium battery or a collection of individual cells.\nIn your letter, you enclose drawings and describe the configurations for two modules that\ncontain several lithium metal cells, each containing less than 2 grams of lithium. The\nindividual cells are permanently mounted in a module. The aggregate lithium content of the\ncells contained in each module is more than 2 grams. You state no electrical connections\nexist between the cells until the module is installed in the equipment.\nProvided no electrical connections exist between the cells, the configurations described in\nyour letter would constitute a collection of individual cells and not a battery. Once the\nmodule is installed into the device and electrical connections are made, these configurations\nshould be described and transported as a lithium battery contained in equipment. You should\nnote once installed in the device, the lithium metal cells are connected and the module\nconstitutes a battery.\nPrior to transportation in commerce, the cells in the module or the lithium battery installed in\nthe device must meet all applicable HMR requirements including UN design type testing.\nI hope this information is helpful. Please contact us if you require additional assistance.\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nPhilips Medical systems\nHeartstream\n2301 5th Ave., Suite 200\nSeattle, WA 98 12 1\n206 664-58 10 (direct)\nSENT ELECTRONICALLY\nFebruary 29,2008\nMr. Kevin Leary\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\nRe: Request for Interpretation of \"lithium battery\"\nDear Mr. Leary:\nThank you for taking the time to speak with me earlier this week. As you suggested, I am sending\nthis description of some concepts regarding pre-packaged primary lithium cells . I am requesting an\ninterpretation as to whether these assemblies would be considered a \"lithium battery\" or a collection\nof individual cells for transport purposes.\nWe are currently developing new equipment that will be powered by lithium primary cells. For user\nconvenience, these cells would typically be assembled into a removable battery. As in most\nbatteries, electrical connections inside the battery, between cells, would combine the cells into the\nrequired configuration of series and parallel cell stacks.\nThese batteries would contain sufficient cells to exceed 2 grams of lithium metal per battery and so\nwould be subject to the more rigorous hazardous material regulations for shipping which are\napplicable to batteries of this size.\nWe would like to explore alternate designs that would provide the same convenience to the user as a\nbattery, but could also be considered a collection of individual cells, rather than a \"battery\" for\ntransport purposes. The key concept being proposed is a module comprising a collection of\nindividual cells which are held in position in a housing. However, unlike a battery, the module\ncontains no electrical connections between any of the cells. Connections between the cells are made\nonly when the module is installed into the equipment.\nFigures 1 and 2 show two possible concepts, although other variations are also possible. Both share\nthe central feature that no cell-to-cell electrical connection exists within the modules. In figure 1, the\nmodule holds multiple individual cells with an enclosure. The enclosure has openings in one side so\nthat when the module is installed in the equipment, contacts in the equipment housing extend into the\nmodule and make the required electrical connections with the cells. When the module is shipped not\ninstalled in the equipment, it contains no electrical connections between the cells.\n\n<<<PAGE 3>>>\n\nPhilips Medical Systems 2-29-08\nFigure 2 also shows a module containing individual cells within an enclosure. Unlike the concept in\nfigure I , the individual cell terminals are electrically connected to individual contacts on the side of\nthe enclosure. This has the advantage of consolidating the electrical interface to a more convenient\nlocation and eliminates openings in the module enclosure. However, it maintains the key feature that\nall the cells remain electrically isolated from each other until the module is installed in the\nequipment.\nPlease note that these figures are intended only to represent the basic concept being discussed. They\ndo not represent complete designs.\nI am requesting an interpretation as to whether these module concepts, which have no electrical\nconnections between cells, would be considered \"lithium batteries\" or whether they could be treated\nas shipments of cells, assuming they are shipped not installed in equipment.\nPlease feel free to contact me if you need additional information.\nRegards,\nAlan Greenstein\nProject Manager\nPage 2 of 4\n\n<<<PAGE 4>>>\n\nPhilips Medical Systems\nMODULE TOP VIEW\n1 I ' ' I\nI\nI I I I '\nI\nCELL (TYPICAL)\nI\n' I I\nI\nI I I ' I\nI\nEXPOSED (-) END\nI CELLS ENCLOSED IN MODULE. NO CONNECTIONS BETWEEN CELLS\ni\nI\n1\nI\ni\nI\nI\nEXTENDING DOWN I\nFROM EQUIPMENT REACH\nINTO MODULE TO FORM ELECTRICAL I\nI\nI\nFigure 1.\nBattery module with individual cells. Contacts in equipment make contact directly with cell\nterminals\nPage 3 of 4\n\n<<<PAGE 5>>>\n\nPhilips Medical Systems\n!\nCELL\nINDIVIDUAL (+) CELL CONTACT\nEXPLODED VIEW INDIVIDUAL (-) CELL CONTACT\nINDIVIDUAL CELL TERMINALS I\nBROUGHT OUT TO INDIVIDUAL CONTACTS 1\nASSEMBLED MODULE\nCELL-TO-CELL CONNECTIONS MADE ONLY WHEN MODULE\nIS INSTALLED IN EQUIPMENT\nFigure 2\nBattery module where individual cell terminals are connected to individual external contacts.\nPage 4 of 4","truncated":false,"body_characters":6163}