{"operation":"document","citation":"11-0143","title":"ICC Nexergy — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-08-29","effective_on":null,"summary":"11-0143 response to ICC Nexergy concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0143.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0143.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0143","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110143.pdf","body":"<<>>\n\n1200 New Jersey Avenue SE\nu.s. Department Washington. DC 20590\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nAUG 29 2011\nMr. David Brongiel\nApplications Engineering Manager\nICC Nexergy\n4 Westbrook Corporate Center, Suite 900\nWestchester, IL 60154\nRef. No.: 11-0143\nDear Mr. Brongiel:\nThis responds to your June 9, 2011 letter and subsequent telephone conversation with a member\nofmy staffregarding the requirements in the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180) applicable to a lithium battery pack. In your letter you describe a device that uses\nthree 95 Watt-hour lithium ion battery packs, each ofwhich consists of24, 1.1 Ah cells in a\n4S6P configuration. The three lithium ion batteries described in your letter are electrically\nconnected within the device but utilize a micro controller to ensure that the battery pack will not\nactivate during transportation. Specifically, you ask ifthe configuration described in your letter\nmay be considered separate lithium ion batteries under the HMR.\nNo. Since the three battery packs are electrically connected, the configuration described in your\nletter meets the definition ofa battery as defined in section 38.3 ofthe United Nations Manual of\nTests and Criteria. The definition states that a battery means one or more cells which are\nelectrically connected together by a permanent means, including case, terminals and markings.\nThe lithium battery described in your letter exceeds the size requirements outlined in § 172.102,\nSpecial Provision 188. This battery pack may be transported in conformance with requirements\nin §172.1 02, Special Provision 189 by highway or rail only and § 173.185 as Class 9 by\nhighway, rail, vessel and aircraft.\nI hope this answers your inquiry. If you need additional assistance, please contact the Standards\nand Rulemaking Division at (202) 366-8553.\niI1S~\nBen Supko\nActing Chief, Standards Development\nStandards and Rulemaking Division\n\n<<>>\n\nICCNEXERGY™\nIntelligent Power Solutions\nBen Supko June 9, 2011\nOffice of Hazardous Material Standards\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRe: SPMU Lithium Ion Battery Design\nDear Mr. Supko:\nI am writing this letter in regards to our lithium ion battery configuration in a power unit for\nportable ultrasound stand, known as the SPMU (Stand Power Management Unit). We would\nlike confirmation from PHMSA that our current understanding of the battery configuration meets\nthe requirements for the small battery exception in 49 CFR § 171.102, Special Provision 188 of\nthe U.S. Hazardous Materials Regulations (HMR) and thus is exempt from the requirements of\nthe HMR. Our current understanding is based primarily on the battery definitions in the UN\nManual of Tests and Criteria, the regulatory requirements for lithium ion batteries found at 49\nCFR § 173.185.\nSPMU\nThe SPMU is a medical grade Stand Power Management Unit with universal AC input and\nprovides +24VDC output, rated at 275W. The SPMU can be fitted with three optional lithium ion\nbatteries. The SPMU charges the batteries while plugged into AC power. If AC power is\nremoved from the SPMU, the SPMU automatically runs the system off of the battery packs.\nLithium Ion Batteries Designed for SPMU\nICCNexergy uses three 95Wh lithium ion batteries that consist of 24 1.1 Ah cells in a 4S6P\nconfiguration. The batteries are still under development; however, they are being designed to\nbe certified in accordance with the requirements of UN Manual of Tests and Criteria.\nICCNexergy will ship the batteries in a carton of three units to the customer, who would like to\ninstall the batteries in the SPMU prior to shipping the SPMU.\nThe batteries are installed in the SPMU by securely fastening them to an aluminum plate and\nheld in place with a set of M5 screws.\nThe batteries ship from ICCNexergy in \"shut-down\" mode, which means the charge and\ndischarge FETs are \"off', and the battery is electrically isolated at its connector contacts. The\nbatteries can \"wake up\" only when all three batteries have been installed in an SPMU, and the\nSPMU is connected to AC power.\n4 Westbrook Corporate Center Suite 900 IWestchester, !L 60154\nPhone: 708-836-3800 IFax: 708-836-3801\nChina Germany USA Mexico Hong Kong Unfted Kingdom\n\n<<>>\n\nIf the SPMU is connected to AC power, the SPMU microcontroller will be active and can detect\nthat all three batteries have been installed. Only after the SPMU microcontroller detects that all\nthree batteries have been installed that the SPMU will apply a 12VDC charge voltage to the\nbatteries to \"wake\" them up. At this time, the battery microcontrollers are now active, but the\ncharge and discharge FETs remain \"off\", The SPMU and batteries can now communicate via\n5MBus.\nThe battery charge and discharge FETs remain \"off\" until the SPMU provides an operational\n5MBus command to the batteries.\nDuring preparation for shipment, the SPMU will not have AC power applied so that the batteries\nwill always remain in the \"shut-down\" mode.\nThe three batteries are electrically connected together within the SPMU. That is, within the\nSPMU, all three batteries have the battery positive terminal connected together, and all three\nbatteries have the battery negative terminal connected together. The batteries are isolated from\neach other via the batteries being in shut-down mode and their charge and discharge FETs\nbeing \"off\". A diagram illustrating the SPMU battery system is enclosed with this letter.\nIn summary, we understand our battery design consists of three individual batteries that meet\nthe requirements of the small battery exception found in 49 CFR § 171.102, Special Provision\n188 of the U.S. HMR, and, when these batteries are installed in the SPMU and offered for\ntransport, the SPMU also qualifies for the exceptions found in Special Provision 188 (provided\nthe SPMU has not been plugged into AC power). We would appreciate written confirmation\nfrom PHMSA that our understanding of these lithium ion battery regulatory requirements is\nconsistent with previous interpretation letters issued by PHMSA on this issue.\nThank you very much for taking the time to respond to our letter. Please feel free to contact me\nwith any questions.\nSincerely,\nG~f~.J\nDavid Bronglel\nApplications Engineering Manager\nICCl\\lexergy\ndbronq iel@ iccnexe rgy.com\n0: 708.316.4428\nM: 708.890.2515\n4 Westbrook Corporate Center Suite 900 IWestchester, IL 60154\nPhone: 708-836-3800 IFax: 708-836-3801\nChina Germany USA MeKico Hong Kong United Kingdom\n\n<<>>\n\nICCNEXERGY \"\nIntelligent Power Solu Ions\nSPMU Concept\n-------------------------------------~\n,l Westbrook Corpo!att! Center Suite 900 IWestche$ter. IL 6015 ~\nPhone. 708-836-3800 IFax: 708·836·38u1\nChin.J GBlTI1sny USA Hong Kong Uni/t!d Kingdom\n\n<<>>\n\nICC NEXERGY ~\nIntelhgent Power Soilltlons\nSPMU dummy sample with 1 battery installed\n-+ Westbrook Corporate Canter SUite 900 IWestchester, lL 6015,1\nPhone. 708-836-3800 IFax: 708-836-3801\nChin\" GennllllY USA Me/lico HOllg Kong U/JI led Kingdom\n\n<<>>\n\nICCNEXERGY\"\nIntelligent Power Solutions\nSPMU underside view:\n4 Westbrook Corporate Ct3nler SllIl 900 IWestchester, IL 60154\nP~,one 708-836-3800 I Fax. 708-836·3801\nChina GemlBflY USA Me ieo Hong Kong United Kingdom\n\n<<>>\n\ncc EXERGY '~\nIntelligent Power Solu1ions\nSPMU with all three batteries installed\nEnd .\n4 Westbrook Corporate Center SUite 900 IWestchester. IL 6015:1\nPhone: 708·836·3800 IFax: 708-836-3801\nChmil GermRny USA M 1<;CO Hong Kong United Kingdom","truncated":false,"body_characters":7614}