{"operation":"document","citation":"12-0078","title":"Rechargeable Battery Association — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-06-27","effective_on":null,"summary":"12-0078 response to Rechargeable Battery Association concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0078.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0078.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0078","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120078.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nJUN 2 7 2012\nMr. George Kerchner\nExecutive Director\nRechargeable Battery Association\n1776 K Street, NW .\nWashington, DC 20006\nRef. No.: 12-0078\nDear Mr. Kerchner:\nThis responds to your March 19, 2012letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the lithium ion battery\ntesting requirements. The requirements you address are contained in Section 38.3 of the\nUnited Nations (UN) Manual of Test and Criteria and are implemented through the\nprovisions of§ 173.185 of the HMR. Your questions are. paraphrased and answered as\nfollows:\nQl. Section 38.3.3 of the UN Manual ofTest and Criteria states \"when batteries\n(comprised of successfully-tested component cells) that have passed all applicable\ntests are electrically connected to form a battery assembly in which the aggregate\nlithium content of all anodes, when fully charged, is more than 500 g, or in the case\nof a lithium ion battery, with a Watt-hour rating of more than 6,200 Watt-hours, that\nbattery assembly does not need to be tested if it is equipped with a system capable of\nmonitoring the battery assembly and preventing short circuits, or over discharge\nbetween the batteries in the assembly and any overheat or overcharge of the battery\nassembly.\"\nAre Tests 1, 2, 3, 4, and 5 in Section 38.3 of the UN Manual of Tests and Criteria the\nonly applicable tests for batteries designed for use in a battery assembly over 6200\nWatt-hours when the batteries are not equipped with overcharge protection and the\nbattery assembly affords such protection?\nAl. The answer is yes, provided that the component cells passed all applicable tests as\nrequired in Section 38.3.\n02. If the answer to 01 is yes, must the completed battery assembly be subjected to the\nTest 7 overcharge test?\n\n<<<PAGE 2>>>\n\nA2. The answer is no. Per Section 38.3.3( d) of the UN Manual of Test and Criteria,\nwhen testing rechargeable batteries under Test 7, batteries not equipped with\novercharge protection that are designed for use only in a battery assembly (which\naffords such protection) are not subject to the requirements of this test.\nI hope this satisfies your inquiry. Please contact us if we can be of furth~r assistance.\nSincerely,\n~~~~--\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nMarch 19,2012\nN·,ekels\n1j/(3. 195\nLt.l-h;um fu+feri-es\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRe: Request for Intetpretation on UN Lithium Battery Testing Requirements\nI am writing to request a clarification on an issue related to testing large lithium ion\nbattery assemblies with a Watt-hour rating of over 6200 in accordance with section 38.3\nofthe UN Manual of Tests and Criteria.\nThe lithium battery tests in the UN Manual of Tests and Criteria contain the following\nproviSion:\nWhen batteries that have passed all applicable tests [emphasis added] are\nelectrically connected to form a battery assembly in which the aggregate\nlithium content of all anodes, when fully charged, is more than 500 g, or\nin the case of a lithium ion battery, with a Watt-hour rating of more than\n6200 Watt-hours, that battery assembly does not need to be tested if it is\nequipped with a system capable of monitoring the battery assembly and\npreventing short circuits, or over discharge between the batteries in the\nassembly and any overheat or overcharge of the battery assembly.\nOur understanding of the \"applicable tests\" for lithium ion batteries used in battery\nassemblies as referred to in the provision above may in some cases only be Tests 1, 2, 3,\n4 and 5. That is because Tests 6 and 8 are only applicable to cells (not batteries), and\nTest 7 (Overcharge) is not required in cases where batteries are not equipped with\novercharge protection and are designed for use only in a battery assembly, which affords\nsuch protection. (See last paragraph in Section 38.3.3(d).)\nTherefore, we would like confirmation from your office on the following two questions:\n1. Please confirm that Tests 1, 2, 3, 4 and 5 in Section 38.3 ofthe UN Manual of Tests\nand Criteria may in some cases be the only \"applicable tests\" for batteries designed\nfor use in a battery assembly over 6200 Wh when the batteries are not equipped with\novercharge protection and the battery assembly affords such protection.\n(Z-00'7~\nPRBA- The Rechargeable Battery Association\n1776 K Street, NW\nWashington, DC 20006\n202.719.4987\n\n<<<PAGE 4>>>\n\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\nPage 2\n2. In the case above when only Tests 1, 2, 3, 4 and 5 are required for the batteries and no\novercharge test is conducted, must the completed battery assembly be subject to the\nTest 7 Overcharge test?\n* * *\nPlease contact me at 202.719.4109 ifyou have any questions regarding this request for\ninterpretation.\nThank you for your assistance.\nSincerely,\nGeorge Kerchner\nExecutive Director","truncated":false,"body_characters":5177}