{"operation":"document","citation":"13-0156","title":"Matthews Associates, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-09-06","effective_on":null,"summary":"13-0156 response to Matthews Associates, Inc concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0156.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0156.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0156","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130156.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\nSEP 0 6 1013\nMr. George Foucher\nVice President Quality Assurance\nMatthews Associates, Inc.\n220 Power Court\nSanford, FL 32771\nRef. No.: 13-0156\nDear Mr. Foucher:\nThis is in response to your email dated July 26, 2013, concerning requirements under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for testing of lithium ion\nbatteries. The specific 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. Specifically you ask whether a failure of a test chamber to maintain the\nconditions specified in the test procedure constitute a \"no test\" or an \"under test\" and what\nactions are required.\nThe UN Manual of Test and Criteria describe procedures for conducting a series of tests\ndesigned to simulate certain transport and abuse conditions. Test T.1 (Altitude Simulation)\nsimulates air transport under low-pressure conditions. The procedure requires test cells and\nbatteries to be stored at a pressure of 11.6 kPa or less for at least six hours at ambient\ntemperature (20 ± 5 °C). In your letter, you stated that while performing an annual\ncalibration of the altitude chamber, it was determined that the pressure sensor had a 3%\nerror and the pressure during tests reached 11.95 kPa during the 6 hour test. This increased\npressure was not constant during the entire 6 hour test rather it was the maximum observed\npressure during the test.\nThe procedure for the altitude simulation test requires the cells or batteries to be stored at a\npressure of 11.6 kPa or less for 6 hours. The test procedure permits lower pressures, but not\nhigher pressures. Results from tests conducted on cells at a higher than permitted pressures\nare not valid. To compensate for a known percentage error in the test sensor, you may\nconsider subjecting cells and batteries to a lower pressure or conducting more frequent\ncalibration of test equipment to ensure accuracy.\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\ns&1ffi . .\nDc!mer Billings ~\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nINFOCNTR (PHMSA)\nMonday, July 29, 2013 2:24 PM\nDrakeford, Carolyn (PHMSA)\nFW: 49 CFR 173.185 Interpretation Request\nHi Carolyn,\nThis caller requested we submit this e-mail as a formal letter of interpretation.\nThanks,\nVictoria\nFrom: George Foucher [rnailto:GFoucher@maifl.com]\nSent: Friday, July 26, 2013 4:18PM\nTo: INFOCNTR (PHMSA)\nCc: Arvin Blank; Phil Perreault; Judy Perreault\nSubject: RE: 49 CFR 173.185 Interpretation Request\nDear Sir or Madam,\nPlease respond with your interpretation of the following:\nCompany Information:\nMathews Associates, Inc. manufactures battery assemblies, including both lithium metal (primary) and lithium-ion\n(rechargeable). We also perform testing in accordance with \"The Recommendations on the Transport of Dangerous\nGoods, Manual of Tests and Criteria\", Section 38.3 \"Lithium metal and Lithium-ion batteries in our \"A2Z\" test lab.\nRelevant Reference from \"The Recommendations on the Transport of Dangerous Goods, Manual of Tests\nand Criteria\" I Revision 5, Amendment 1 I Section 38.3.4 excerpt:\n38.3.4.1 Test T 1: Altitude simulation\n38.3.4.1.1 Purpose\nThis test simulates air transport under low-pressure conditions.\n38.3.4.1.2 Test procedure\nTest cells and batteries shall be stored at a pressure of 11.6 kPa or less for at least six hours\n1\n------·· ----·\n\n<<<PAGE 3>>>\n\nat ambient temperature (20 ± 5 °C}.\n38.3.4.1.3 Requirement\nCells and batteries meet this requirement if there is no leakage, no venting, no disassembly,\nno rupture and no fire and if the open circuit voltage of each test cell or battery after testing is not less than\n90% of its voltage immediately prior to this procedure. The requirement relating to voltage is not applicable\nto test cells and batteries at fully discharged states.\nSituation:\nWhen performing our annual calibration of the altitude chamber, it was shown that the pressure sensor was off\n3% at the 11.6 kPa pressure (50,000 feet) required for Tl altitude. Based on the 3% sensor deviation, the actual\npressure made excursions up to a pressure of almost 11.95kpa (49,200 ft} during the 6 hour test. This pressure\nwas not constant during the entire 6 hour test due to the vacuum pump cycling but was the maximum pressure\nrealized during the test.\nQuestion:\nWe would like to know if this would be classified as a no test or under test and what actions by Mathews, if any,\nare needed?\nThank you,\n~fl-7~\n1lta p~ 2~.4~\nMathews Associates, Inc.\n220 Power Court\nSanford, FL 32771\nUSA\nPH: 407-323-3390\nFax: 407-323-3115\ne-mail: gfoucher@maifl.com\nWebsite: www.maifl.com\nThis transmittal may contain company confidential, proprietary and/or information regulated by the International Traffic\nin Arms Regulations (ITAR) and may be subject to U.S. Government Export Control Laws. This information is\nintended for use only by the recipient. Transfer of this information to any foreign party, whether in the U.S. or abroad,\nwithout Department of State approval and/or licensing is prohibited.\nIf you are not the intended recipient, please contact the originator, George J. Foucher, (407)323-3390, to return all the\noriginal copies. Thank You.\nIT AR: This transmittal may contain company confidential, proprietary and/or information regulated by the\nInternational Traffic in Arms Regulations (ITAR) and may be subject to U.S. Government Export Control Laws.\nThis information is intended for use only by the recipient. Transfer of this information to any foreign party,\nwhether in the U.S. or abroad, without Department of State approval and/or licensing is prohibited.\n2","truncated":false,"body_characters":5929}