{"operation":"document","citation":"08-0173","title":"Cannondale Sports Group — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-08-12","effective_on":null,"summary":"08-0173 response to Cannondale Sports Group concerning 173.185, 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0173.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0173.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0173","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080173.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave . S.E\nWash~ngton, DC 20590\nAUG 1 2 2008\nMr. Zach Krapfl\nCannondale Sports Group\nWorld Headquarters\n4902 Hammersley Road\nMadison, WI 537 1 1\nRef. No.: 08-0173\nDear Mr. Krapfl:\nThis is in response to your July 8,2008 letter concerning the appropriate classification of an\nelectric bicycle powered by a.lithium-ion battery under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 17 1-1 80). You state that the battery used to power the bicycle contains\n20.79 grams of equivalent lithium content. Further, you state that the battery is in the process\nof being tested pursuant to the requirements of the UN Manual of Tests and Criteria, Fourth\nRevised Edition. Specifically, you ask if your electric bicycle equipped with a lithium-ion\nbattery may be classed and described as \"Battery powered vehicle\" or \"Battery powered\nequipment\" (UN3 17 1 ) under the HMR.\nThe answer is yes. An electric bicycle powered by a lithium-ion battery is most .\nappropriately described as a \"Battery-powered vehicle\" under the HMR. A vehicle powered\nby a lithium battery must satisfj the requirements of 5 173.220(d), which requires the battery\nto be of a type that has successfully passed each test in the UN Manual of Tests and Criteria\nas specified in 5 173.185, unless approved by the Associate Administrator.\nI hope this information is helpful.\nSincerely,\nSusan Gorsky d\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nJuly 8,2008\nDELIVERED VIA EMAIL\nMr. Edward Mazzullo\nDirector of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDear Mr. Mazzullo:\n1 am writing to request confirmation from your office that our electric bicycle powered by\na lithium ion battery can be classified and shipped as a Battery powered vehicle or Battery\npowered equipment (UN3171). Exhibit A on the following page contains a picture of the\nbicycle.\nThe lithium ion battery that will be used to power the electric bicycle contains 20.79\ngrams of equivalent lithium content (ELC). The battery is in the process of being tested pursuant\nto the requirements in the LrN Manual of Tests and Criteria, Fourth Revised Edition.\nOur electric bicycle is similar in many respects to a Segway in that it is a mobility device.\nIn 2005, your office issued a letter stating that a Segway powered by a lithium ion battery may\nbe classified and shipped as a Battery powered vehicle pursuant to 49 CFR 173.220 of the U.S.\nhazardous materials regulations. (See Ref. No. 05-0076.) Therefore, we are of the opinion that\nthe correct classification for the electric bicycle with a lithium ion battery installed is Battery\npowered vehicle or Battery powered equipment (UN3 17 1 ). This would be consistent with the\nlanguage contained in Special Provision 134 that states \"Examples of such items are electrically-\npowered cars, lawn mowers, wheelchairs, and other mobility aids.\" (Emphasis added.) This\nclassification also is consistent with how these types of bicycles are being packaged and offered\nfor transport in Europe where these products are widely used.\nTherefore, please confirm in writing that our electric bicycle shipped with a lithium ion\nbattery installed may be classified and shipped as a Battery powered vehicle or Battery powered\nequipment (UN3 17 1 ).\nworld headquarters\n4902 hammersley road\nmadison, wi 5371 1\np 608.268.2468\nf 608.268.2466\nA DIVISION OF DOREL INDUSTRIES\n\n<<<PAGE 3>>>\n\nThank you for your assistance on this matter. If you have any questions regarding our\nelectric bicycle or lithium ion battery, I can be reached at 303.65 1.6255.\nSincerely,\nWXW\nZach Krapfl\nEXHIBIT A\nworld headquarters\n4902 hammersley road\nmadison, wi 5371 1\np 608.268.2468\nf 608.268.2466\nA DIVISION OF DOREL INDUSTRLES","truncated":false,"body_characters":3948}