{"operation":"document","citation":"13-0126","title":"Naval Surface Warfare Center Energy Power & Interconnect Technologies Division — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-08-21","effective_on":null,"summary":"13-0126 response to Naval Surface Warfare Center Energy Power & Interconnect Technologies Division concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0126.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0126.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0126","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130126.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nAUG 2 1 2013\nMr. Mark Tisher\nCrane Division\nNaval Surface Warfare Center\nEnergy Power & Interconnect Technologies Division\n300 Highway 361, Bldg. 3235 GSX\nCrane, IN 47522-5001\nRef. No.: 13-0126\nDear Mr. Tisher:\nThis responds to your June 13, 2013 email and subsequent conversation with a member of\nmy staff requesting clarification of the requirements in the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to design testing of lithium ion\nbatteries. The requirements you address are contained in Section 38.3 of the United\nNations (UN) Manual of Tests and Criteria and are implemented through the provisions of\n§ 173.185 of the HMR. In your letter and in telephone conversations with my staff, you\ndescribed a cylindrical battery comprised of 35 individual cells. The battery is inserted into\nan aluminum housing that is part of a battery powered device. The device with the\nbatteries is then placed into a case for shipping. You asked if you could conduct the T3\n(shock) and the T4 (vibration) tests with the battery installed in the aluminum housing or in\na transit box because the battery itself is not equipped with mounts to secure it to the testing\nmachine.\nEach test in Section 38.3 must be conducted on the battery itself without equipment or\npackaging. In the situation you described, the battery must be subjected to each of the\ntests, including the shock and the vibration tests outside of the device or any packaging.\nI hope this answers your inquiry. If you have further questions, please do not hesitate to\ncontact this office.\n·-~---~---··---- -~~~\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nLeary, Kevin (PHMSA)\nThursday, June 13, 2013 3:04 PM\nDrakeford, Carolyn (PHMSA)\nFW: lithium battery testing question\nbattery photo.jpg; device drawing.jpg\n13-Dt.l{p\nPlease enter this request into the system for response.\nKevin\n-----Original Message-----\nFrom: Tisher, Mark T CIV NSWC Crane, GXS [mailto:mark.tisher@navv.mil]\nSent: Thursday, June 13, 2013 10:20 AM\nTo: Leary, Kevin (PHMSA)\nSubject: lithium battery testing question\nKevin,\nI'm looking for an interpretation of Section 38.3 of the UN Manual for T3 transportation vibration and T4 shock. The\nbattery has no mounting provisions other than inserting it into the cylindrical housing for the device (see attached). For\ntransportation, the device is then placed in a transit case. I'm trying to determine the acceptable test configuration for\nthese two tests. I don't see how we can test it without the housing. Can it be tested in the transit case? If not, the\nhousing has rubber bumpers that can be seen in the device drawing file. The rubber bumpers are restrained only by a\nhouse clamp within the groove. Would we fixture to the rubber bumpers or to the housing itself? We started by fixturing\ndirectly to the housing, but the device manufacturer stated that previous testing of a similar device fixture to the\nbumpers. We switched to fixturing to the rubber bumpers, but the rubber creates play and it loosened up after the first\nsweep causing problems.\nOne more question: for shock, the cells and battery are blow the large cell and large battery definition, but if we test it in\nthe housing the mass is up around 70 pounds, so 150g is a lot of force and I'm wondering if there is consideration for this.\nv/r\nMark Tisher\nCrane Division, Naval Surface Warfare Center\n300 Hwy 361\nCrane, In 47522\nph (812) 854-5912\ncell (812) 361-5269\nfax(812)854-2043\nEmail: mark.tisher@navv.mil\nhttp://www.navsea.navv.mil/nswc/crane/Lists/customerfeedback/NewForm.aspx\nHarnessing the Power of Technology for the Warfighter\nNotice: FOR OFFICIAL USE ONLY- this transmission contains material covered by the Privacy Act of 1974 and should be\nviewed only by personnel having an official \"need to know.\" If you are not the intended recipient, be aware that any\ndisclosure, copying, distribution or use of the content of this information is prohibited. If you have received this\ncommunication in error, please notify me immediately by email and delete the original message.\"\n1\n\n<<<PAGE 3>>>","truncated":false,"body_characters":4250}