A2Z Test Lab a division of MAI — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Pipeline and Hazardous Materials Safety Administration DEC 2 2011 Arvin Blank Environmental Engineering Manager A2Z Test Lab a division of MAl 220 Power Court Sanford, Florida 32771 Reference No. 11-0265 Dear Mr. Blank: This is in response to your October 26, 2011 letter pertaining to the testing of batteries in accordance with the United Nations (UN) Manual of Test and Criteria, 5th revised edition. You reference Section 38.3.4.2.3 which requires cells and batteries to meet the requirement of the T2 - Thermal Shock Test. This test requires there is no mass loss, no leakage, no venting, no disassembly, no rupture, and no fire if the open circuit voltage of each cell or battery testing is not less than 90% of its voltage immediately prior to this procedure. You ask the Pipeline and Hazardous Materials Safety Administration (PHMSA) to clarify whether a crack in the outer casing of a battery you tested in accordance with the T2-Thermal Shock Test as show in the attached picture would constitute a "rupture." The answer is yes. In Section 38.3.2.2 of the UN Manual of Test and Criteria, 5th revised edition, a "rupture" is defined as mechanical failure of a cell container or battery case induced by an internal or external case, resulting in exposure or spillage but not the ejection of solid materials. It is the opinion of this Office that a crack in the case of the battery as depicted in your photograph would constitute a "rupture" and thus, be a failure of the T2- Thermal Shock Test. I hope this satisfies your request. Sincerely, -7.#~~- T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2AndrtttJs $>113;/S/ & {krl(s 26 October 2011 II-/~ ~S- To: PHMSA.hm-infocenter@dot.gov From: Arvin Blank (ablank@maifl.com) Dear PHMSA We are performing Department ofTransportation Testing (Tl -T5) as per the Manual of Tests and Criteria 5th revised edition. Specifica!ly: Section ofregulations 38.3.4.2.3 T2 - Thermal Shock Section: 38.3.4.2.3 Requirement Cells and batteries meet this requirement ifthere is no mass loss, no leakage, no venting, no disassembly, no rupture and no fire and ifthe open circuit voltage ofeach cell or battery after testing is not less than 90% of its voltage immediately prior to this procedure. The requirement relating to voltage is not applicable to test cells and batteries at fully discharged states. One ofthe batteries tested developed a crack in the case during the Thermal Shock Test. See picture below. Our customer has tasked us to get an official opinion from the Department of Transportation that clarifies ifthis constitutes a rupture or not. Sincerely Arvin Blank A2Z Test Lab ablank@maifl.com 407-432-8869#