{"operation":"document","citation":"10-0173","title":"Intertek — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-10-13","effective_on":null,"summary":"10-0173 response to Intertek concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0173.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0173.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0173","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100173.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materia~s\nSafety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nOCT 1 3 2010\nMr. Rich Byczek\nSite Manager\nIntertek\n13200 Levan Road\nLivonia, MI 48150\nRef. No.: 10-0173\nDear Mr. Byczek:\nThis is in response to your August 17,2010, email requesting clarification ofrequirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-type testing\nof lithium ion batteries. In your email, you describe a lithium ion battery module comprised of\nelectrically connected cells that serves as a component of a larger lithium battery pack. You state\nthis lithium ion battery module is transported between manufacturing facilities and thus is subject to\ntesting in accordance with the United Nations (l1N) Manual ofTests and Criteria. In your email,\nyou note this module is equipped with a protective insulator that prevents external access to the\nbattery terminals. You ask ifyou must remove the protective insulator to conduct the appropriate\ntests or note that the terminals are inaccessible.\nThe specific requirements you address are contained in Section 38.3 ofthe UN Manual ofTests and\nCriteria and are implemented through the provisions of § 173.185 ofthe HMR. Prior to\ntransportation in commerce, the lithium ion battery module must successfully pass all ofthe\napplicable tests in Section 38.3 ofthe UN Manual of Tests and Criteria, including the T.5 (short\ncircuit test) and the T.7 (overcharge test). The lithium battery module must be subjected to all of\nthe appropriate design type tests in the same configuration as when it will be installed in the larger\nbattery pack. In this case if a physical barrier such as a cover must be removed prior to installation\nin the larger battery pack, it must be removed for design type testing.\nI hope this information is helpful. Ifyou have further questions, please contact this office.\nSincerely,\n~.5~\nBen Supko\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nDrakeford. Carolyn (PHMSA)\nLearv{\n§li3·-t~5\n~+h iu m ]!:a.tJert'e.s\nFrom: Betts, Charles (PHMSA) ID-O\",~\nSent: Tuesday, August 17, 2010 9:53 AM\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: Interpretation requested regarding test applicability for Lithium -Ion Batteries\nAttachments: SN200241.jpg\nFrom: Rich Byczek Intertek [mailto:rich.byczek@intertek.com]\nSent: Tuesday, August 17, 20109:46 AM\nTo: Betts, Charles (PHMSA)\nCc: Dawoomi Hong; Tom O'Hara Interteki Fadi Alawi Intertek\nSubject: Interpretation requested regarding test applicability for Lithium -Ion Batteries\nCharles,\nMy name is Rich Byczek, and I am the site manager for Intertek's Safety and Performance lab in Detroit Michigan.\nI am writing you on behalf of our client, who had some questions related the UN Manual of Tests and Criteria, applicability\nof tests.\nSpecifically, this client has a battery (rack of cells), which utilizes a protective insulator to prevent external access to the\nbattery terminals (photo attached).\nIt should be noted that this is an interim module-level part, the cells are electrically connected internal to the module, that\nis later connected as part of a full battery pack.\nThis level does undergo transport between manufacturing facilities.\nAs a test lab performing the testing, how should we treat this sample for the short circuit (T5) and overcharge (T7) tests.\nAs the terminals are physically blocked, do I just note that the terminals are inaccessible, preventing an external short\ncircuit or overcharge condition? Or, do I remove/bypass the protective cover to gain access to the terminals.\nPer client review, this feature is specifically added to prevent a short circuit or inadvertent voltage applied to the\nterminals. Therefore they consider it to be a protective device. The concern is validity of removing this device to perform\nthe test, as this would be similar to bypassing a diode, fuse or other protective device.\nI can be contacted via email or Mobile phone. My contact information is listed below.\nAlso, if there is a different contact I should use, please let me know.\nThank you,\nRich Byczek\nSite Manager\nPhone: 734-591-9161\nIntertek\n13200 Levan Road\nLivonia, MI48150\nFax: 734-432-0555\nMobile: 248-219-1099\nRich. Byczek@intertek.com\nwww.intertek.com\nCONFIDENTIALITY NOTICE\n1\n\n<<<PAGE 3>>>","truncated":false,"body_characters":4366}