{"operation":"document","citation":"09-0182","title":"GE Sensing & Inspection Technologies — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-10-13","effective_on":null,"summary":"09-0182 response to GE Sensing & Inspection Technologies concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0182.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0182.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0182","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090182.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave., SE\nWashington, DC 20590\nOCT 1 3 2009\nMr. Tom Piggin\nElectronic Engineer\nGE Sensing & Inspection Technologies\nFir Tree Lane\nGroby\n~eicestershire\nLE6 OFH\nUK\nRef. No. 09-0 1 82\nDear Mr. Piggin:\nThis responds to your August 4,2009 request for clarification of the requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium\nbattery packs. Specifically, you ask if the configurations described in your letter constitute a\nsingle lithium ion battery pack or separate lithium ion batteries.\nIn your letter you describe two battery packs, each of which consists of five lithium batteries\nin a single housing. Each of the lithium ion batteries contains two or more cells and will\nhave an aggregate lithium content of 8.1 grams (99Wh).\nIn the first example, the five lithium batteries lead to a single connection, but remain\nelectrically isolated while in transportation. Provided the batteries remain isolated during\ntransportation, this configuration would constitute separate lithium ion batteries for purposes\nof the HMR, and may be transported in conformance with requirements in $172.102, Special\nProvision 189 by highway and 4 173.185 as a Class 9 by air and vessel.\nIn your second example, the batteries are electrically connected but utilize diodes to ensure\nthat the battery pack will not activate during transportation. In this case, the five battery\npacks installed in the power supply described in your letter are electrically connected and\nmust be described as a single lithium ion battery pack with an aggregate lithium content of\n\n<<<PAGE 2>>>\n\n40.5 grams equivalent lithium content (500Wh) and transported as Class 9 material in\nconformance with the requirements of 8 173.185.\nI hope this answers your inquiry. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely, 8\n~ h a r l e s ' ~ . Betts\nDevelopment\nMaterials Standards\n\n<<<PAGE 3>>>\n\nPage 1 of 2\nDrakeford, Carolyn (PHMSA)\n,,,,, .. .*-,*-,,-. . .,-. ..'--\", ,<**,% ~ ,\"%..\nFrom: INFOCNTR (PHMSA)\nSent: Tuesday, August 04,2009 3:40 PM\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: battery regulations\nAttachments: battery configuration.jpg; battery configuration2.,ipg\nFrom: Piggin, Thomas (GE EntSol, SensInsp) [mailto:Thomas.Piggin@ge.com]\nSent: Tuesday, August 04, 2009 11:27 AM\nTo: INFOCNTR (PHMSA)\nSubject: battery regulations\nDear SirIMadam\nI have a query regarding lithium battery regulations, attached is how we intend to configure our battery pack, I\nwould greatly appreciate it if you could reply with a comment saying whether the US DOT would allow this to be\nair transported.. .\nTo explain the two drawings:\nthe second one is identical to the first except that it has diodes in place so that if a single cell fails the others do\nnot try to discharge into it.\nthe first drawing shows the 5 batteries housed together mechanically, they are not connected electrically as all the\nwires connect to a single connector, but are isolated from one another. The batteries are also definitely classed as\nbatteries as they contain two or more cells within each of the 5 x 3.7 27Ah batteries.\nTo explain the 'key' section: We will have some sort of tool, which will plug into the connector and therefore\nconnect the batteries together in our chosen configuration to form a single 500Wh battery. This would only be\nconnected when the product is not in transport.\nIf having the individual batteries connected in a single case then this is no problem, we could individually package\neach battery as well if required. It is also worth mentioning that the batteries will be contained in equipment and so\nI believe subject to packing instruction 967.\nJust to also explain that I am aware each individual battery will need to be UN tested if it hasn't already been so\ndone by the manufacturer or if the manufacturer produces these batteries using several smaller cells that have\nalready been tested.\nIf you could just give a small comment saying whether you would allow this configuration then that would be great.\nRegards\nTom Piggin\nElectronic Engineer\nGE\nSensing & Inspection Technologies\n4 : +44 (0)116 2317100\n4 : +44 (0)116 2317269 (direct)\nE: Thomas.Piqqin@,qe.com\n~.se-~~nsi!!an_s~.e_cf..io_n...c~ .IL!\nFir tree lane\nGroby\nLeicestersh ire\n\n<<<PAGE 4>>>\n\nPage 2 of 2\nLE6 OFH\nUK\nDruck Limited\n8/4/2009\n\n<<<PAGE 5>>>\n\nhousing\nAll 5 batteries housed together mechanically,\nbut not electrically connected\n\n<<<PAGE 6>>>\n\nPage 1 of 5\nBoothe, Deborah (PHMSA)\n-~ -\nFrom: INFOCNTR (PHMSA)\nSent: Friday, August 14, 2009 10:26 AM\nTo: Boothe, Deborah (PHMSA)\nSubject: FW: battery regulations\nDebbie,\nThis gentleman emailed the information center about a letter you are working on. See Below. It appears you\nmight be able to handle this by phone. Could you please give him a call and discuss his follow-up question.\n-Rob Benedict\n- -\" .,,...- -. . . ,,.,, ..., .. . - . . . ,.... . ....,,~. , . ..,..,.....\nFrom: Piggin, Thomas (GE EntSol, SensInsp) [mailto:Thomas.Piggin@ge.com]\nSent: Friday, August 14, 2009 10:14 AM\nTo: INFOCNTR (PHMSA)\nSubject: RE: battery regulations\nHi Rob\nI have received some information from a colleague within another GE business and he has told me that the US\nDOT has approved their battery pack, which is the same configuration as how we intend to connect our batteries\nto the equipment. Is there any way you can confirm this approval in some way?\nTheir system has two 80Wh batteries that are mechanically connected by a shrink wrapped case. The wiring from\neach battery goes to a PCB where they are paralleled together to electrically form one single 160Wh battery. The\npcb connection then connects the pcb and battery to the instrument, but this connection is not present for\ntransportation. However the connection that parallels the batteries together is still present and so I am enquiring\nas to how the DOT regards these as separate batteries?\nI hope you can provide some sort of answer on this.\nRegards\nTom\n-p-\"-m-,#\nFrom: TNFOCNTR@dot.gov [mailto:INFOCNTR@dot.gov]\nSent: 06 August 2009 13:25\nTo: Piggin, Thomas (GE EntSol, SensInsp)\nSubject: RE: battery regulations\nDear Thomas Piggin,\nWe have received your request for a written interpretation regarding the hazardous\nmaterials regulations (49 CFR Parts 171-180). Unfortunately, the Hazardous\nMaterials Information Center cannot provide written interpretation/guidance via\nemail. The Office of Hazardous Materials Standards has a mechanism in place to\nprovide written guidance in the form of a letter of interpretation. Typically,\nwritten letters of interpretation are responded to at minimum of approximately 6\nweeks from when they are received by the Office of Hazardous Materials Standards.\nHowever, delivery time of a written interpretation can vary markedly based on topic\ncomplexity and the backlog of letters to be completed. Let me know if you are\ninterested in a letter of interpretation and 1 will forward your request to the\n\n<<<PAGE 7>>>\n\nPage 2 of 5\nOffice of Hazardous Materials Standards to begin the process.\nYou may contact the Hazardous Materials Information Center, which is staffed with\nregulatory specialists who can quickly answer your questions by phone, Monday\nthrough Friday, 9 AM - 5 PM EST at +1(202) 366-4488.\nSincerely,\nRob Benedict, Hazardous Materials Specialist\nAn e-mail response from this office is considered informal guidance. Formal\nguidance may be requested in accordance with 49 CFR 105.20.\nhttp://hazmat.dot.qov/infocent.htm\nFrom: Piggin, Thomas (GE EntSol, SensInsp) [mailto:Thomas.Piggin@ge.com]\nSent: Wednesday, August 05, 2009 9:31 AM\nTo: INFOCNTR (PHMSA)\nSubject: RE: battery regulations\nHi Rob\nIs there no way you can provide me a confirmation by email. I have no problem ringirlg the hotline, but then the\nonly proof I have is what I write about the conversation I've had with the DOT over the phone. All I am asking for\nis the following ...\nThe DOTS stance on whether they consider a mechanically connected group of batteries i.e in a single case, as\none large battery or several smaller batteries even though none of them are electrically connected.\nWhether the DOT would class battery wiring connected to a single connector as electrically connected even\nthough there is no possibility of an electrical circuit being created.\nMy direct number is 0044 1 16231 7269 if you want to call me\nRegards\nTom\nFrom: INFOCNTR@dot.gov [mailto:INFOCNTR@dot.gov]\nSent: 05 August 2009 13:06\nTo: Piggin, Thomas (GE EntSol, SensInsp)\nSubject: RE: battery regulations\nDear Thomas Piggin,\nWe have received your inquiry about the hazardous materials regulations (HMR) (49\nCFR Parts 171-1801.\nThe HMR prescribes the requirements of the Department of Transportation governing\nthe offering and transportation of hazardous materials in interstate, intrastate,\nand foreign commerce by rail car, aircraft, motor vehicle, and vessel. While we\ncannot provide an exhaustive list of each applicable requirement or a formal\ninterpretation of the regulations via email, we suggest you review the attached\nwritten letters of interpreation for additional information the definition of cells\nand batteries. The previous letters of interpretation are available at the\nfollowing URLs:\n\n<<<PAGE 8>>>\n\nPage 3 of 5\nIf you require additional assistance, you may contact the Hazardous Materials\nInformation Center, which is staffed with regulatory specialists who can quickly\nanswer your questions by phone, Monday through Friday, 9 AM - 5 PM EST at +1(202)\n366-4488.\nSincerely,\nRob ene edict, Hazardous Materials Specialist\nAn e-mail response from this office is considered informal guidance. Formal\nguidance may be requested in accordance with 49 CFR 105.20.\nhttp://hazmat.dot.gov/infocent.htm\nFrom: Piggin, Thomas (GE EntSol, SensInsp) [mailto:Thomas.Piggin@ge.com]\nSent: Wednesday, August 05, 2009 5:21 AM\nTo: IlUFOClUTR (PHMSA)\nSubject: RE: battery regulations\nHi Rob\nThanks for the quick response. 6 weeks is going to be too long to wait in order to get an answer to this. I think\nthere are two key areas within the configuration that could affect things. What I am seeking clarification on is the\nfactors that would make you consider a battery a battery or a battery as a series of smaller batteries. From all the\nregulations I have read, IATA, ICAO etc it states that an electrical connection between two smaller batteries would\nbe classed as a large battery. I am happy with this rule. However I have heard that some authorities would\nconsider several smaller batteries connected in a single pack as a single battery. What is your position on this?\nThe second issue is that we would want to connect all the wires from the individual batteries into a single common\nconnector, however the batteries won't be connected to each other electrically, it will just be the wires lumped into\na single connector, e.g. 5 batteries, both with a positive and negative wire and then all 10 wires connected into a\n1 Oway connector.\nTherefore the response I am after is whether the US DOT would regard the two above scenarios as single\nbatteries or several smaller batteries.\nAlso I am struggling to find the information on the link you gave me, could you point me in the direction of some\nmore specific areas of the document?\nI hope you can help.\nRegards\nTom\n\n<<<PAGE 9>>>\n\nPage 4 of 5\nFrom: INFOCIUTR@dot.gov [mailto::[NFOCNTR@dot.gov]\nSent: 04 August 2009 20:41\nTo: Piggin, Thomas (GE EntSol, SensInsp)\nSubject: RE: battery regulations\nDear Thomas Piggin,\nWe have received your request for a written letter of interpretation regarding the\nhazardous materials regulations (49 CFR Parts 171-180). The hazardous materials\nregulations are available at the following URL:\nTypically, written letters of interpretation are responded to at minimum of\napproximately 6 weeks from when they are received by the Office of Hazardous\nMaterials Standards. However, delivery time of a written interpretation can vary\nmarkedly based on topic complexity and the backlog of letters to be completed.\nSincerely,\nRob Benedict, Hazardous Materials Specialist\nAn e-mail response from this office is considered informal guidance. Formal\nguidance may be requested in accordance with 4 9 CFR 105.20.\nhttp://hazmat.dot.qov/infocent.htm\nFrom: Piggin, Thomas (GE EntSol, SensInsp) [mailto:Thomas.Piggin@ge.com]\nSent: Tuesday, August 04, 2009 11:27 AM\nTo: INFOCNTR (PHMSA)\nSubject: battery regulations\nDear SirIMadam\nI have a query regarding lithium battery regulations, attached is how we intend to configure our battery pack, I\nwould greatly appreciate it if you could reply with a comment saying whether the US DOT would allow this to be\nair transported.. .\nTo explain the two drawings:\nthe second one is identical to the first except that it has diodes in place so that if a single cell fails the others do\nnot try to discharge into it.\nthe first drawing shows the 5 batteries housed together mechanically, they are not connected electrically as all the\nwires connect to a single connector, but are isolated from one another. The batteries are also definitely classed as\nbatteries as they contain two or more cells within each of the 5 x 3.7 27Ah batteries.\nTo explain the 'key' section: We will have some sort of tool, which will plug into the connector and therefore\nconnect the batteries together in our chosen configuration to form a single 500Wh battery. This would only be\nconnected when the product is not in transport.\nIf having the individual batteries connected in a single case then this is no problem, we could individually package\neach battery as well if required. It is also worth mentioning that the batteries will be contained in equipment and so\nI believe subject to packing instruction 967.\nJust to also explain that I am aware each individual battery will need to be LIN tested if it hasn't already been so\ndone by the manufacturer or if the manufacturer produces these batteries using several smaller cells that have","truncated":false,"body_characters":14044}