{"operation":"document","citation":"11-0265","title":"A2Z Test Lab a division of MAI — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-12-02","effective_on":null,"summary":"11-0265 response to A2Z Test Lab a division of MAI concerning 173.159.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0265.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0265.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0265","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110265.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department 1200 New Jersey Avenue SE\nof Transportation Washington. DC 20590\nPipeline and Hazardous\nMaterials Safety\nAdministration \n DEC 2 2011\nArvin Blank\nEnvironmental Engineering Manager\nA2Z Test Lab a division of MAl\n220 Power Court\nSanford, Florida 32771\nReference No. 11-0265\nDear Mr. Blank:\nThis is in response to your October 26, 2011 letter pertaining to the testing of batteries in\naccordance with the United Nations (UN) Manual of Test and Criteria, 5th revised edition.\nYou reference Section 38.3.4.2.3 which requires cells and batteries to meet the\nrequirement of the T2 - Thermal Shock Test. This test requires there is no mass loss, no\nleakage, no venting, no disassembly, no rupture, and no fire if the open circuit voltage of\neach cell or battery testing is not less than 90% of its voltage immediately prior to this\nprocedure. You ask the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) to clarify whether a crack in the outer casing of a battery you tested in\naccordance with the T2-Thermal Shock Test as show in the attached picture would\nconstitute a \"rupture.\"\nThe answer is yes. In Section 38.3.2.2 of the UN Manual of Test and Criteria, 5th revised\nedition, a \"rupture\" is defined as mechanical failure of a cell container or battery case\ninduced by an internal or external case, resulting in exposure or spillage but not the\nejection of solid materials. It is the opinion of this Office that a crack in the case of the\nbattery as depicted in your photograph would constitute a \"rupture\" and thus, be a failure\nof the T2- Thermal Shock Test.\nI hope this satisfies your request.\nSincerely,\n-7.#~~-\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nAndrtttJs\n$>113;/S/\n& {krl(s\n26 October 2011 II-/~ ~S-\nTo: PHMSA.hm-infocenter@dot.gov\nFrom: Arvin Blank (ablank@maifl.com)\nDear PHMSA\nWe are performing Department ofTransportation Testing (Tl -T5) as per the Manual of Tests\nand Criteria 5th revised edition.\nSpecifica!ly: Section ofregulations 38.3.4.2.3 T2 - Thermal Shock\nSection: 38.3.4.2.3 Requirement\nCells and batteries meet this requirement ifthere is no mass loss, no leakage, no venting,\nno disassembly, no rupture and no fire and ifthe open circuit voltage ofeach cell or battery after\ntesting is not less than 90% of its voltage immediately prior to this procedure. The requirement\nrelating to voltage is not applicable to test cells and batteries at fully discharged states.\nOne ofthe batteries tested developed a crack in the case during the Thermal Shock Test. See\npicture below. Our customer has tasked us to get an official opinion from the Department of\nTransportation that clarifies ifthis constitutes a rupture or not.\nSincerely\nArvin Blank\nA2Z Test Lab\nablank@maifl.com\n407-432-8869","truncated":false,"body_characters":2821}