{"operation":"document","citation":"11-0025","title":"Securaplane Technologies, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-03-15","effective_on":null,"summary":"11-0025 response to Securaplane Technologies, Inc. concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0025.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0025.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0025","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110025.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Avenue, SE\nWashington, OC 20590\nPipeline and Hazardous Materials\nSafety Administration\nMAR 1 5 2011\nMr. Rod Iverson\nSecuraplane Technologies, Inc.\n10900 N. Stallard Place\nTucson, AZ 85737\nRef. No.: 11-0025\nDear Mr. Iverson:\nThis responds to your January 31, 2011 email requesting clarification ofthe requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design type\ntesting requirements for a lithium ion battery. According to your letter, your company, located\nin Tucson, AZ contracted with another company based in San Jose, CA to assemble and test a\nlithium ion battery pack in accordance with the applicable requirements ofUnited Nations\n(UN) Manual of Tests and Criteria. The battery packs assembled by this company passed the\napplicable tests. You wish to continue manufacturing this battery pack at your Tucson, AZ\nfacility and you ask us to confirm your understanding that your company may manufacture\nlithium ion batteries that are identical to the previously manufactured and tested lithium ion\nbatteries without subjecting them to additional testing.\nThe tests outlined in the UN Manual ofTests and Criteria for lithium batteries are design type\ntests. Provided the lithium ion batteries you intend to manufacture are identical to a previously\ntested design type, additional testing is not required.\nI hope this answers your inquiry. Ifyou need additional assistance, please contact the\nStandards and Rulemaking Division.\nSincerely,\nBen Supko\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom: INFOCNTR (PHMSA) II - 002S\nSent: Monday, January 31,20112:23 PM\no To: Drakeford, Carolyn (PHMSA)\nSubject: Interp Letter Request FW: Li battery UN test report applicability\nFrom: Rod Iverson [mailto:riverson@securaplane.com]\nSent: Monday, January 31, 201110:28 AM\nTo: INFOCNTR (PHMSA)\nSubject: Li battery UN test report applicability\nCompany Introduction: Securaplane Technologies, Inc. is a Tucson, AZ based Engineering and\nManufacturing company. Battery design and manufacturing for the Commercial and General Aviation\nmarket is approximately 25% of our business.\nSubject: Securaplane designed and produced a 7.4 volt, 3.3Amp Hour Li Ion Polymer Battery pack for\nthe Boeing 787 airplane. The LI-Ion-Polymer battery pack has been subjected to and passed all\nrequired FAA and Boeing environmental test requirements.\nSecuraplane released a build to print production contract to Rose Electronics 2030 Ringwood\nAve San Jose, CA 95131 for the assembly and test of the Securaplane battery pack design. The\nproduction quantities of the Ii-Ion battery contract required that the units meet the UN test\nrequirements for transportation of the packs. Securaplane working with Rose Electronics issued\na contract to Mobile Power Solutions, Beaverton, OR for the UN Transportation test activity. The\nUnits passed and test report number R1-695 was issued along with Certificate of Compliance for\nthe Battery packs. The packs are identified with Securaplane part number 100-2602-01 using Kokam\nSLPB-526495 cells. Rose Electronics completed assemblies are all shipped to Securaplane for a\nfinal test prior to delivery to our customer.\nSecuraplane plans to return the manufacturing of the Li Ion Battery to our facility in Tucson, AZ in\nFebruary 2011. The Rose Electronics manufactured battery used for the UN test is identical to\nthe product to be manufactured by Securaplane. Hence, the UN test results and Certificate of\nCompliance are considered directly applicable to the Securaplane Li Ion Battery product.\nSecuraplane respectfully requests your concurrence with this assessment regarding the UN test and\nCertificate of compliance.\nThe request: Please provide a formal letter of interpretation regarding this transfer/application of the\nJune 2010 UN test results and Certificate of Compliance for the Securaplane manufactured Li Ion\nBattery.\nRod Iverson\nSecuraplane Technologies, Inc\n10900 N Stallard Place\nTucson, AZ 85737\nDirect: (520) 425-8121\nCell: (520) 548-9465\nEmail: riverson@securaplane.com\n1","truncated":false,"body_characters":4172}