{"operation":"document","citation":"09-0261","title":"Westgate Transportation Services, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-01-22","effective_on":null,"summary":"09-0261 response to Westgate Transportation Services, Inc. concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0261.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0261.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0261","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090261.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue. SE\nWashington. DC 20590\n')r~, N 2 2 2010\nMr. Richard 1. Lloyd\nWestgate Transportation Services, Inc.\n31 Bastian Lane\nAllentown, PA 18104\nRef. No.: 09-0261\nDear Mr. Lloyd:\nThis responds to your letter dated November 6,2009, regarding the requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the\ntransportation of lithium cells or batteries, including a lithium polymer cell or battery and\na lithium-ion cell or battery. Specifically, you ask about regulatory requirements for cells\nthat are connected in parallel and whether the requirements apply to any cells connected\ntogether in any configuration.\nSection 173.185(a)(3) specifies that a lithium cell or battery, including a lithium\npolymer cell or battery and a lithium-ion cell or battery must be equipped with an\neffective means to prevent a dangerous reverse current flow (e.g., diodes, fuses,\netc.) if a battery contains cells or series ofcells that are connected in parallel (Le.,\na closed circuit in which the current divides into two or more paths before\nrecombining to complete the circuit). The requirement in §173.185(a)(3) means\nthat ifa battery contains cells or series of cells that are connected in parallel they\nmust be equipped with an effective means to prevent a dangerous reverse current\nflow.\nI hope this infonnation is helpfuL If we can be offurther assistance, please contact us.\nSincerely yours,\n'~~~ 0-Mhades\nE. Betts\nChIef, Standards Office\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nPage 1 of2\nDrakeford, Carolyn (PHMSA)\nFrom: INFOCNTR (PHMSA) h...VJg rUM\nSent: Friday, November 06, 2009 11:13 AM\nTo: Drakeford, Carolyn (PHMSA) ~ ll3.. 1~'3J\nSubject: FW: Lithium Batteries Li+h I um13(:(.t+er't()\nAttachments: Diagram Sketch Series and Paraliel.pdf DGt-D2..1o I\nFrom: dickchar@enter.net [mailto:dickchar@enter.net]\nSent: Friday, November 06,2009 10:56 AM\nTo: INFOCNTR (PHMSA)\nSubject: Lithium Batteries\nI will appreciate a letter of interpretation clarifying Section 173.185 (a) (3) addressing lithium cells or\nbatteries, including a lithium polymer cell or battery and a lithium-ion cell or battery, that must conform\nin all ofthe following requirements:\nParagraph (a) (3) states: \"Be equipped with an effective means to prevent dangerous reverse current\nflow (e.g., diodes, fuses, etc.) if a battery contains cells or series of cells that are connected in parallel.\"\nI need to understand the meaning of \"cells that are connected in paralle!'!. I have attached a sketch\nshowing both series and parallel configurations of battery connections. Both configurations are\ncommon and batteries may be shipped with units wired in either configuration.\nIs the regulation (a) (3) interpreted literally to apply to a battery containing cells or series of cells wired\nin parallel as shown in my attachment or is the regulation interpreted more generically by applying it to\nany cells connected together?\nThank you for your response as your interpretation will provide guidance on the shipment of assembled\nunits.\nPlease acknowledge receipt of this correspondence and, ifpossible, advise approximately when a\nresponse will be issued.\nRichard J.\nLloyd\nnbsp; &nb sp; 31 Bastian\nLane\nbsp; &nbs p; Allentown, P A 181 04\nTelephone: 610-3983954\n&n\nbsp; E-mail: di9kcltE!r@~!lter.nc;;t\n] 116/2009\n\n<<<PAGE 3>>>\n\nPage 2 of2\nDick\nRichard J. Lloyd\nWestgate Transporation Services, Inc.\n2299 Brodhead Road\nBethlehem, P A 18020\nOffice: 610-866-8001\nHome: 610-398-3954\ndick.l1oyd@westgate-global-Iogistics.com\n111612009\n\n<<<PAGE 4>>>\n\nCONNECTION\nPARALLEL\nCONNECTION\nET\n11/3/09\n\n<<<PAGE 5>>>\n\nI~\nMaxim> AQp Notes >BATIERY MANAGEMENT POWER-SUPPLY CIRCUITS\nKeywords: Reverse-Current Circuitry Protection Jan 31,2001\nAPPLICATION NOTE 636\nReverse-Current Circuitry Protection\nBattery reversal can be fatal to portable equipment. However, numerous circuits can protect against the\nbackward installation of batteries and other overcurrent-causing conditions.\nBattery-operated equipment is prone to the consequences of batteries installed backward, accidental short\ncircuits, and other types of careless use. The effects of a reversed battery are critical. Unfortunately, it is difficult\nto guard against this situation.\nTo make equipment resistant to batteries installed backward, you must design either a mechanical block to the\nreverse installation or an electrical safeguard that prevents ill effects when the reverse installation occurs.\nMechanical protection can be a one-way connector that accepts the battery only when oriented with the correct\npolarity.\nFor example, 9V radio batteries have mechanically dissimilar terminals, although a user fumbling with the\nmechanical connection can still momentarily make the reverse electrical connection. On the other hand, you can\nconfigure connectors for rechargeable battery packs so that momentary reverse connections are impossible\nunless the user modifies the connector.\nThe greatest challenge, however, is in applications powered by one or more single-cell batteries such as AAalkaline,\nNiCd, and nickel-metal-hydride types. In general, these batteries offer no mechanical means for\npreventing the reversal of one or more cells. For these systems, a designer must ensure that any flow of reverse\ncurrent is low enough to avoid damaging the circuit or the battery. A variety of circuits can provide this\nassurance.\nDiodes Provide the Simplest Protection\nThe simplest form of battery-reversal protection is a diode in series with the positive supply line (Figure la).\nThe diode allows current from a correctly installed battery to flow to the load and blocks current flow to a\nbackward-installed battery. This solution has two major drawbacks: The diode must handle the full load current,\nand its forward voltage drop shortens the equipment's operating time. (The regulator output is one diode drop\nbelow the battery voltage, so the regulator drops out prematurely.)\nIf the application calls for an alkaline or other type of battery with relatively high output impedance, you can\nguard against reverse installations using a parallel (shunt) diode. The circuit in Figure Ib is simple but far from\nideal. This approach protects the load yet draws high current from the shorted battery. As before, the diode\nmust be able to handle the high current.","truncated":false,"body_characters":6424}