{"operation":"document","citation":"10-0017","title":"MGA Research Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-03-16","effective_on":null,"summary":"10-0017 response to MGA Research Corporation concerning 172.101, 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100017.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation MAR 1 6 2010 1200 New Jersey Ave, SE\nPipeline and Hazardous Materials Washington, D.C. 20590\nSafety Administration\nMr. Michael Greiner\nMGA Research Corporation\n12790 Main Road\nAkron, NY 14001\nRef. No.: 10-0017\nDear Mr. Greiner:\nThis is in response to your January 26, 2010 email requesting clarification of requirements in\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type\ntesting of lithium ion batteries. The specific requirements you address are contained in Section\n38.3 of the 51h Revised Edition of the United Nations Manual of Tests and Criteria. Currently,\nthe HMR reference the 4th Revised Edition of the United Nations Manual of Tests and Criteria.\nPHMSA proposed to incorporate the 5th revised edition in a notice of proposed rulemaking\npublished on January 11,2010 (HM-224F; 75 FR 1301).\nYour letter describes two lithium ion hybrid electric vehicle battery assemblies consisting of\nelectrically connected cells and modules. Your questions have been paraphrased and answered\nas follows:\nQ1. You ask us to confirm your understanding of the appropriate number and condition of cells\nand batteries required to be tested in accordance with the 5th Revised Edition of the United\nNations Manual of Tests and Criteria.\nA 1. The infonnation you provided in your letter pertaining to the number and condition of\nlithium cells and batteries required to complete the design type tests outlined in the 5th Revised\nEdition of the United Nations Manual of Tests and Criteria is correct.\nQ2. Provided the lithium battery modules or lithium battery assemblies are internally\ndisconnected when offered for transportation and transported, is the lithium battery module or\nlithium battery pack subject to the UN design type tests?\nA2. Provided the lithium cells comprising the battery module or the lithium battery modules\ncomprising the battery assembly are not electrically connected, then each component is\nconsidered an individual battery for the purposes of testing. However, once electrically\nconnected, the entire battery module or battery assembly must be tested as a single battery.\nQ3. If the battery cells and modules successfully pass the UN design type tests, is the battery\nassembly subject to testing?\n\n<<<PAGE 2>>>\n\nA3. The answer to this question depends on the size of the battery assembly. The 4th revised\nedition of the UN Manual of Tests and Criteria does not require further testing of battery\nassemblies comprised of successfully tested cells and batteries when the aggregate lithium\ncontent of all anodes, when fully charged, is more than 500 g or in the case of a lithium ion\nbattery, is more than 6200 Watt-hours provided certain conditions are met. This means that\nbattery assemblies with not more than 500 g aggregate lithium content or in the case of a lithium\nion battery, is not more than 6200 Watt-hours are subject to each of the appropriate tests in the\nquantity indicated.\nThe 5th revised edition would permit alternative testing for battery assemblies in which the\naggregate lithium content of all anodes, when fully charged, is not more than 500 g, or in the\ncase of a lithium ion battery, a Watt-hour rating of not more than 6200 Watt-hours, that is\nassembled from cells or batteries that have passed all applicable tests. In this case, one battery\nassembly in a fully charged state must be tested under Tests 3,4, and 5, and, in addition, Test 7\nin the case of a rechargeable battery assembly. For a rechargeable battery assembly, the\nassembly shall have been cycled at least 25 cycles.\nI hope this answers your inquiry. If you have further questions, please do not hesitate to contact\nthis office.\nCharles E. Betts\nhief, Standards Development\nO' of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nLeQr'j\n~ Il?.~ I D f\n~ 173.\nPage 1 of3\nDrakeford. Carolyn (PHMSA)\nFrom: Betts, Charles (PHMSA) r,~\nSent: Tuesday, January 26,20107:38 AM \\0- DOl1\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: UN testing requirements\nImportance: High\nCarolyn,\nPlease log the attached email from Mr. Michael Greiner as a new request for interpretation and assign to Kevin.\nThanks,\nCharles\nFrom: Ke, Charles (PHMSA)\nSent: Monday, January 25, 2010 9:19 AM\nTo: Michael Greiner\nCc: Ke, Charles (PHMSA); Betts, Charles (PHMSA)\nSubject: RE: UN testing requirements\nPlease send your inquiry to: Mr. Charles Betts at charles.betts@dot.gov\nFrom: Michael Greiner [mailto:Michael.greiner@mgaresearch.com]\nSent: Friday, January 22, 2010 4:21 PM\nTo: Ke, Charles (PHMSA)\nSubject: RE: UN testing requirements\nHello Charles,\nThank you for the reply. It seems I will need an official written reply. Could you please direct me to the proper email\naddress and/or phone number?\nBest Regards,\nMichael Greiner\nMGA Research Corporation\n12790 Main Road\nAkron, NY 14001\nPhone: 716-542-5515\nFax: 716-542-4437\nmichael.greiner@mgaresearch.com\n\"MGA's newsletter is now available electronically. Ifyou are interested in receiving our enewsletter\ndon't wait any longer, sigll up now!11\"\nFrom: charles.ke@dot.gov [mailto:charles.ke@dot.gov]\nSent: Friday, January 22,20101:57 PM\nTo: Michael.greiner@mgaresearch.com\nCc: charles.ke@dot.gov; GKerchner@wileyrein.com\n1126/2010\n\n<<<PAGE 4>>>\n\nPage 2 of3\nSubject: RE: UN testing requirements\nHi Michael,\nMy reply here should be considered as an opinion not an official reply. If you need a written\nofficial reply you need to request to our Standards Office.\n1. Your understanding on Item I is correct.\n2. There is no provision in the test scheme to allow you tie in the transport conditions (with\ninternal circuit disconnected) with alternative testing requirements. If I understand you\ncorrectly, with internal circuit disconnected between each module, would you have a\nbattery pack? I do not quite understand what are you trying to accomplish.\n3. The last paragraph on page 397 of the 5th ed. Of the Test Manual of Section 38.3\nanswers your question.\nIf I can be of further assistance please advise.\nCharles Ke\nFrom: Michael Greiner [mailto:Michael.greiner@mgaresearch.com]\nSent: Thursday, January 21, 2010 1:47 PM\nTo: Ke, Charles (PHMSA)\nCc: 'Kerchner, George'; 'Helen Kaleto'; 'Jason Gilham'; chris.sumner@mgaresearch.com\nSubject: UN testing requirements\nHello Mr. Ke\nThis e-mail is in regards to some questions that came up from a customer of mine.\nOur customer is building a rechargeable pack that is going to be used in an HEV. They need to do testing from\nthe cell level to the module level and finally at the pack level in accordance to the new Rev 5 standard coming out\nin 2011. There are going to be 2 different size modules (one consisting of 20 cells and one consisting of 10\ncells). The final packs are going to be a grouping of these. The questions are as follows:\n1. Is the information below for amounts correct?\nCells:\n10 cells at first cycle in a fully charged state (T1-T5)\n10 cells at first cycle at 50% of the design rated capacity (Impact prismatic)\n10 cells at first cycle in a fully discharged state (T8)\n10 cells after 50 cycles ending in a fully discharged state (T8)\nTotal: 40 cells\nModules:\n2 batteries at first cycle fully charged (T1-T5)\n2 batteries after 25 cycles ending fully charged (T1-T5)\nTotal: 4 batteries (assuming that the overcharge test is not required because the modules do not have\novercharge protection and are going to be used in a larger assembly which affords such protection.)\nThis would be 4 per style (module with 20 cells, module with 10 cells)\nIf one of the modules is under 12kg? 4 batteries at each state mentioned above will be needed for a total\nof8 small.\nPack:\n2 pack ending fully charged after 25 cycles (T3-T5, T7)\nTotal: 2 packs\n1/26/2010\n\n<<<PAGE 5>>>\n\nPage 3 of3\n2. 3. If the battery packs and or modules are being shipped with the contactors not engaged (with the internal\ncircuit disconnected), will they need to be when performing the tests, mainly the electrical tests? (short\ncircuit, overcharge)\nIf the cells and modules pass the UN testing is there a stipulation that says the pack would not need to be\ntested?\nBest Regards,\nMichael Greiner\nMGA Research Corporation\n12790 Main Road\nAkron, NY 14001\nPhone: 716-542-5515\nFax: 716-542-4437\nmichael. greiner@mgaresearch.com\n\"MGA's newsletter is now available electronically. Ifyou are interested in receiving our enewsletter\ndon't wait any longer, sign up now!!!\"\n1126/2010\n\n<<<PAGE 6>>>\n\nThe 5th revised edition made several amendments applicable to the testing requirement of\nbattery assemblies.\nWe have reproduced the information you provided in your letter in the following chart:\nA total of 40 cells are subject to the appropriate tests as follows:\nTest Number of cells\nTl- T5 10 cells at first cycle in a fully discharged\nState\nT6 For prismatic cells, ten cells are required\n5 cells along the longitudinal axis and,\nseparately 5 cells along the other axes\nT7 Not required for lithium cells\nT8 10 cells at first cycle in a fully discharged\nstate; and\n10 cells at first cycle in a fully discharged\nState\nA total of 8 small batteries (i.e. lithium ion battery with a gross mass of not more than 12 kg)\nand a total of 4 large batteries (i.e. lithium ion battery with a gross mass of more than 12 kg) are\nrequired for the Tl through T5 tests.\nTest Number of Batteries\nTl - T5 4 small batteries, at first cycle, in fully\ncharged states;\n4 small batteries after 50 cycles ending in\nfully charged states.\n2 large batteries at first cycle, in fully\ncharged states; and\n2 large batteries after 25 cycles ending in\nfully charged states.\nT7 Batteries not equipped with overcharge\nprotection that are designed for use\nonly in a battery assembly, which affords\nI such protection, are not subject to\nthe requirements of this test\nWhen testing a lithium ion battery with a Watt-hour rating of not more than 6200 Watt-hours,\nthat is assembled from cells or batteries that have passed all applicable tests, one battery\n\n<<<PAGE 7>>>\n\nassembly in a fully charged state shall be tested under Tests 3, 4, and 5, and, in addition, Test 7\nin the case of a rechargeable battery assembly. For a rechargeable battery assembly, the\nassembly shall have been cycled at least 25 cycles.\nTest Number of Batteries\nT3 - T5 I battery pack in a fully charged state\nT7 1 battery pack in a fully charged state that\nhas been cycled at least 25 cycles.","truncated":false,"body_characters":10341}