{"operation":"document","citation":"12-0097","title":"INOVA Geophysical Equipment Ltd. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-06-15","effective_on":null,"summary":"12-0097 response to INOVA Geophysical Equipment Ltd. concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0097.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0097.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0097","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120097.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 1 5 2012\nMr. l-Iarold Sackett\nINOVA Geophysical Equipment Ltd.\n850 N Dorothy Drive, STE 504\nRichardson, TX 75081\nRef. No.: 12-0097\nDear Mr. Sackett:\nThis is in response to your April 10, 2012 email requesting clarification of requirements in\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to design-\ntype testing of lithium ion batteries. The requirements you address are contained in Section\n38.3 of the United Nations Manual ofTests and Criteria and are implemented through the\nprovisions of§ 173.185 of the HMR.\nIn your letter you describe an assembly comprised of l-3 lithium ion battery packs in an\naluminum enclosure. Each battery pack is less than 100 Wh and comprised of twelve ( 12)\ncomponent cells in a 3s4p configuration. Each battery pack is equipped with individual\nsafety circuits, each with its own connector. The battery packs are tied together when\nassembled in the aluminum enclosure. Specifically, you ask if your configuration\nconstitutes a single lithium ion battery pack or separate lithium ion battery packs.\nBased on your description and the inf01mation enclosed with your letter it appears that the\nassembly described in your letter comprised of two or three electrically connected battery\npacks in an aluminum enclosure meets the defining criteria for a battery as described in\nSection 38.3 of the United Nations Manual of Tests and Criteria. The definition states that a\nbattery means one or more cells which are electrically connected together by a permanent\nmeans, including case, terminals and markings.\nf hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\np~\no.J:·)-·-\nRobert Benedict\nChief~ Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nleaeJ\n~ 1'7 3. 185\nBa. ++e. r i e,s\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments: Leary, Kevin (PHMSA)\nWednesday, April18, 2012 10:00 AM\nDrakeford, Carolyn (PHMSA)\nFW: UNIATA regulations for shipping Lilon batteries\nClass 9 not required.pdf; Dual Battery ASM.pdf; 100-20040.tiff\nPlease log this in for an interp request.\nFrom: Harold Sackett [mailto:Harold.Sackett@inovageo.com]\nSent: Tuesday, April 10, 2012 4:12 PM\nTo: Leary, Kevin (PHMSA)\nCc: John Lybarger\nSubject: UNIATA regulations for shipping Lilon batteries\nDear Mr. Leary,\nAs part of our product offering, we supply a modular Lilon battery assembly to power equipment for our\ncustomers. This allows our customers to leave the equipment in situ and just swap out the batteries and recharge the\nspent batteries. Our original battery pack supplier, Nexergy, worked with us to create a battery that would be compliant\nto UNIATA regulations and still ship without the requirement of a class 9 hazardous material classification. They even\nsupplied a reference letter to back up their opinion.\nSince that time, we have taken on other suppliers and the regulations have also been updated some. Some of the\nsuppliers have questioned us this year whether the original configuration is still compliant with current\nregulations. Could you give us guidance as to if we are compliant and, if not, what we would need to change to become\ncompliant?\nINOVA battery background\nOur battery suppliers build a 3s4p Lilon battery pack with a built-in safety circuit that will shut down the battery in\nevents of overcurrent (or shorts), overvoltage and under voltage. The battery pack capacity is under the 100 WHr limit\nto be compliant with the lithium content portion of the UNIATA regulations. Each of the suppliers must then submit\nsamples of their design to a test house and pass the UNIATA testing requirements. Then they must supply us with a\ncertificate of compliance before they can be added to our approved vendor list.\nWe then designed a modular battery assembly out of extruded aluminum that can be configured to house 1, 2 or 3 of\nthese battery packs. It was our understanding that having individual packs, each compliant with UNIATA regulations and\nindividual safety circuits, each with its own connector, tied together to prevent an imbalance and assembled inside a\nmetal enclosure would allow the modular battery assembly to keep its classification of separate battery packs that are\ncompliant and not require the class 9 shipping classification.\nAttached, you will find the following:\n• The letter we based our earlier classification on\n• The assembly drawing of our modular battery assembly\n• A drawing of the cable (for clarification of how the packs are connected)\nThis is a new product line which will soon be commercialized, and we need to try to get a definitive answer on this\nquestion. Is the assembly still compliant? If not, what is required to bring the assembly into compliance?\nThanks for your help,\nHarold Sackett\n1\n\n<<<PAGE 3>>>\n\nHardware Engineering Manager Cable-less Systems\nINOVA Geophysical Equipment Ltd\n850 N Dorothy Dr, STE 504\nRichardson, Texas 75081-2769\nOffice 972-234-3950 x7592\nMobile 214-649-1708\n2","truncated":false,"body_characters":5150}