{"operation":"document","citation":"09-0303","title":"Electrochem Solutions — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-02-24","effective_on":null,"summary":"09-0303 response to Electrochem Solutions concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0303.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0303.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0303","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090303.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\nFEB 24 2010\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMr. Todd Sweetland\nProduct Engineering Manager\nElectrochem Solutions\n670 Paramount Drive\nRaynham, MA 02767\nRef. No.: 09-0303\nDear Mr. Sweetland:\nThis responds to your December 4, 2009 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of a lithium\nbattery powered device. Specifically you ask ifthe design features described in your letter\nadequately prevent accidental operation ofthe device during transport.\nIn accordance with § 173.185, electrical devices with lithium batteries installed are required to\nbe packed to prevent short circuits and unintentional activation during transport. According to\nyour letter, this device utilizes a single connector that must be manually installed in order to\nactivate. During transport, a red connector is installed in the device to maintain its waterproof\ndesign and ensure the device will not activate. When the device is ready for operation, a\ntechnician will remove the red connector and install the green connector. You further state the\ndevice can only operate when the green connector is installed.\nThe HMR do not prescribe specific means to meet the requirement to prevent accidental\nactivation. However, the method described in your letter appears to meet the intent ofthis\nrequirement.\nI hope this answers your inquiry. If you have further questions, please do not hesitate to contact\nthis office.\n$~~lbjfb\n(~?arleS E. Betts\n,hief, Standards Development\nO~of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nLeart{\nEL:CTROCH:M -§ 173.Y~S\nCREATING TOMORROW\nL:#u'u.rn ~-iter I'\"es\nDecember 04, 2009 OCf- 0.303\nU.S. DOT\nPHIVISA Office of Hazardous Materials Standards\nAttn: PHH-l0\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nDear Sir,\nI am writing this letter on behalf of a customer of ours with a lithium battery\npack shipping inside the device it's meant to power. In regards to 49CFR\n173.185 Lithium Cells and Batteries, we would like a review of section\n173.185(c) Lithium cells or batteries contained in equipment to make sure\nwe are cpmplying correctly with the intent of the rule,\nWe have a series of three Li-primarY\"battery modules all connected together\nin the device. There are several ,protection devices designed into the product\nincluding pack level protection on each string, diode protection and thermal\ncutoffs as well. To ensure that the device will not operate there is a single\nconnector jumper that must be manually installed to power up the device.\nThere is a red jumper installed during shipment to maintain the waterproof\ndesign of the device, and keep the unit powered off. Before operation a\ntechnician removes the sealed red jumper and installs the sealed green\njumper to power up the device. The device will not power up with the red\njumper or with no jumper installed. Only the green jumper will power the\nunit.\nIs this design, as described above considered adequate steps to prevent\naccidental operation during transport ?\nPlease contact me if you have any questions about the details of this design\nor request.\nRegards.\nTodd Sweetlahd\nProduct Engineering Manager - Secondary\n& Battery Compliance Engineer ' ,\n670 Paramount, Drive Raynham, MA.02767\nPh. 78,1-575-0800 Fax 781-575-1545\n'.'. .\nwww.ElectrochemSolutions.com\nA subsidiary of\nI:: GreatbatcH","truncated":false,"body_characters":3489}