# Westgate Transportation Services, Inc. — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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:**

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U.S. Department of Transportation Pipeline and Hazardous Materials
Safety Administration
1200 New Jersey Avenue. SE
Washington. DC 20590
')r~, N 2 2 2010
Mr. Richard 1. Lloyd
Westgate Transportation Services, Inc.
31 Bastian Lane
Allentown, PA 18104
Ref. No.: 09-0261
Dear Mr. Lloyd:
This responds to your letter dated November 6,2009, regarding the requirements in the
Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the
transportation of lithium cells or batteries, including a lithium polymer cell or battery and
a lithium-ion cell or battery. Specifically, you ask about regulatory requirements for cells
that are connected in parallel and whether the requirements apply to any cells connected
together in any configuration.
Section 173.185(a)(3) specifies that a lithium cell or battery, including a lithium
polymer cell or battery and a lithium-ion cell or battery must be equipped with an
effective means to prevent a dangerous reverse current flow (e.g., diodes, fuses,
etc.) if a battery contains cells or series ofcells that are connected in parallel (Le.,
a closed circuit in which the current divides into two or more paths before
recombining to complete the circuit). The requirement in §173.185(a)(3) means
that ifa battery contains cells or series of cells that are connected in parallel they
must be equipped with an effective means to prevent a dangerous reverse current
flow.
I hope this infonnation is helpfuL If we can be offurther assistance, please contact us.
Sincerely yours,
'~~~ 0-Mhades
E. Betts
ChIef, Standards Office
Office of Hazardous Materials Standards

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Page 1 of2
Drakeford, Carolyn (PHMSA)
From: INFOCNTR (PHMSA) h...VJg rUM
Sent: Friday, November 06, 2009 11:13 AM
To: Drakeford, Carolyn (PHMSA) ~ ll3.. 1~'3J
Subject: FW: Lithium Batteries Li+h I um13(:(.t+er't()
Attachments: Diagram Sketch Series and Paraliel.pdf DGt-D2..1o I
From: dickchar@enter.net [mailto:dickchar@enter.net]
Sent: Friday, November 06,2009 10:56 AM
To: INFOCNTR (PHMSA)
Subject: Lithium Batteries
I will appreciate a letter of interpretation clarifying Section 173.185 (a) (3) addressing lithium cells or
batteries, including a lithium polymer cell or battery and a lithium-ion cell or battery, that must conform
in all ofthe following requirements:
Paragraph (a) (3) states: "Be equipped with an effective means to prevent dangerous reverse current
flow (e.g., diodes, fuses, etc.) if a battery contains cells or series of cells that are connected in parallel."
I need to understand the meaning of "cells that are connected in paralle!'!. I have attached a sketch
showing both series and parallel configurations of battery connections. Both configurations are
common and batteries may be shipped with units wired in either configuration.
Is the regulation (a) (3) interpreted literally to apply to a battery containing cells or series of cells wired
in parallel as shown in my attachment or is the regulation interpreted more generically by applying it to
any cells connected together?
Thank you for your response as your interpretation will provide guidance on the shipment of assembled
units.
Please acknowledge receipt of this correspondence and, ifpossible, advise approximately when a
response will be issued.
Richard J.
Lloyd
nbsp; &nb sp; 31 Bastian
Lane
bsp; &nbs p; Allentown, P A 181 04
Telephone: 610-3983954
&n
bsp; E-mail: di9kcltE!r@~!lter.nc;;t
] 116/2009

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Page 2 of2
Dick
Richard J. Lloyd
Westgate Transporation Services, Inc.
2299 Brodhead Road
Bethlehem, P A 18020
Office: 610-866-8001
Home: 610-398-3954
dick.l1oyd@westgate-global-Iogistics.com
111612009

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CONNECTION
PARALLEL
CONNECTION
ET
11/3/09

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I~
Maxim> AQp Notes >BATIERY MANAGEMENT POWER-SUPPLY CIRCUITS
Keywords: Reverse-Current Circuitry Protection Jan 31,2001
APPLICATION NOTE 636
Reverse-Current Circuitry Protection
Battery reversal can be fatal to portable equipment. However, numerous circuits can protect against the
backward installation of batteries and other overcurrent-causing conditions.
Battery-operated equipment is prone to the consequences of batteries installed backward, accidental short
circuits, and other types of careless use. The effects of a reversed battery are critical. Unfortunately, it is difficult
to guard against this situation.
To make equipment resistant to batteries installed backward, you must design either a mechanical block to the
reverse installation or an electrical safeguard that prevents ill effects when the reverse installation occurs.
Mechanical protection can be a one-way connector that accepts the battery only when oriented with the correct
polarity.
For example, 9V radio batteries have mechanically dissimilar terminals, although a user fumbling with the
mechanical connection can still momentarily make the reverse electrical connection. On the other hand, you can
configure connectors for rechargeable battery packs so that momentary reverse connections are impossible
unless the user modifies the connector.
The greatest challenge, however, is in applications powered by one or more single-cell batteries such as AAalkaline,
NiCd, and nickel-metal-hydride types. In general, these batteries offer no mechanical means for
preventing the reversal of one or more cells. For these systems, a designer must ensure that any flow of reverse
current is low enough to avoid damaging the circuit or the battery. A variety of circuits can provide this
assurance.
Diodes Provide the Simplest Protection
The simplest form of battery-reversal protection is a diode in series with the positive supply line (Figure la).
The diode allows current from a correctly installed battery to flow to the load and blocks current flow to a
backward-installed battery. This solution has two major drawbacks: The diode must handle the full load current,
and its forward voltage drop shortens the equipment's operating time. (The regulator output is one diode drop
below the battery voltage, so the regulator drops out prematurely.)
If the application calls for an alkaline or other type of battery with relatively high output impedance, you can
guard against reverse installations using a parallel (shunt) diode. The circuit in Figure Ib is simple but far from
ideal. This approach protects the load yet draws high current from the shorted battery. As before, the diode
must be able to handle the high current.
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