{"operation":"document","citation":"13-0184","title":"Coda Energy — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-11-05","effective_on":null,"summary":"13-0184 response to Coda Energy concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0184.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0184.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0184","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130184.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\nNOV 0 5 2013\nMr. Chris Aragon\nCoda Energy\n135 E. Maple Ave. Unit C\nMonrovia, CA 91 0 16\nRefNo.: 13-0184\nDear Mr. Aragoh:\nThis is a response to your September 6, 2013 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 1 71-180) with regard to the testing of lithium ion\nbatteries. Specifically, you seek confirmation that a new design type of lithium ion battery you\nmanufacture does not require a new test in accordance with the UN Manual of Tests and Criteria\ndue to the minimal changes in design from a previously tested battery. In your letter, you\nprovide the test report for your previously tested design type as well as material safety data\nsheets for both your previous design type and new design type of lithium ion battery.\nIn accordance with§ 173.185(a)(l), each lithium cell or battery must be of a type proven to meet\nthe requirements of each applicable test of the UN Manual of Tests and Criteria found in Section\n38.3. As stated in Section 38.3.2.1 of the UN Manual of Tests and Criteria, cells and batteries,\nwhich differ from a tested type, are required to be retested if, for rechargeable cells and batteries\nthere is a change in Watt-hours of more than 20% or an increase in voltage of more than 20%; or\nthere is a change that would materially affect the test results.\nBased on the documentation you provide, the new design type battery has no changes in\nprotective devices, hardware, and software, safety design in the cells or batteries or venting\nvalve. The size of the device remains the same, as does the number of component cells and the\nconnecting mode and configuration of those cells. Based on the data you supplied the new design\ntype of lithium ion battery exhibits an increase in voltage of approximately 14% and an increase\nin Watt-hours of25%. Since the increase in Watt-hours is over 20% new testing in accordance\nwith Section 38.3.2.1 ofthe UN Manual of Tests and Criteria would be required.\nI hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this office.\nSincerely,\nRobert Benedict\nChief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nU.S Department\nOf Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nRequest for a formal interpretation on newer model L.ithium lon Battery\nReasons, why we believe the new type lishen LP2770120AC{16.5Ah) (earlier model LP27701AB(15Ah)\ndoes not require a new test in reference to UN38.3.2.2 of the UN Manual of Tests and Criteria Fifth\nrevised edition is as follows. There is minimal change in Cathode size, Anode size, material remains the\nsame as referenced 38.3.2.2 (a). Very little change in electrolyte as well. The increase of 9% in primary\ncell Amp hours doesn't equate to the provisions in reference 38.3.2.2 (b). The nominal voltage has\nminimal change, only an increase of 0.45V Volts. Lithium content has a minimal change as well, which is\nwell within limit of UN 38.3.2.2 (a).\nThere are no changes in Protective Devices, hardware or software. There are no changes in safety design\nin cells/batteries, venting valve. Mechanical size remains the same. No change in number of component\ncells. Finally, there is no change in connecting mode or configuration of cells. Also, the model core\nnumber remains the same, LP2770120.\nThe question is can this be shipped normally, may we continue using our Mobile Power Solutions report\nwhich is the UN Battery Transportation Testing Test report C5-726, and not be required to do\nadditional UN testing?\nI have included supporting documentation to further explain the reasons.\n• Mobile Power Solutions Test Report C5-726\n• Certificate of Compliance LP27701AB(15Ah)\n• Certificate of Compliance LP27701AC(16.5Ah)\n• Lishen_Lilon_MSDS_P2770120AB (earlier battery cell)\n• Lishen_Lilon_MSDS_P2770120AC (new battery cell)\n• Product Detail LP27701AB(15Ah)\n• Product Detail LP27701AC(16.5Ah)\n• UN38.3 Lishen Cell Comparison Chart\n•\nPlease contact me if you have any questions.\nThank you very much,\nChris Aragon\n135 E. Maple Ave. unit C\nMonrovia, CA 91016\n(323) 742-2114\n135 E. Maple Monrovia CA 91016\nwww.codaenergy.com","truncated":false,"body_characters":4312}