# Invacare Corporation — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 15-0002
- **title:** Invacare Corporation — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2015-02-20
- **effective on:** Not available
- **summary:** 15-0002 response to Invacare Corporation concerning 175.10.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0002
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150002.pdf
**body:**

<<<PAGE 1>>>

U.S. Department of Transportation
1200 New Jersey Avenue, SE
Pipeline and Hazardous Materials
Washington, DC 20590
Safety Administration
Carol Vierling
FEB 2 0 2015
Acting Regulatory Affairs Manager
Invacare Corporation
One Invacare Way
P.O. Box 4028
Elyria, OH 44036
Ref. No. 15-0002
Dear Ms. Vierling:
This responds to your December 30, 2014 letter requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a portable oxygen
" concentrator (POC). Specifically, you inquire about obtaining approval from the Pipeline
and Hazardous Materials Safety Administration (PHMSA) and the Federal Aviation
aircraft.
Administration (FAA) to allow a passenger to carry and operate the POC on board an
• According to your letter, the POC (trade name Invacare XPO2) is a device for use by
patients requiring high concentrations of oxygen on a supplemental basis. The device in
question is a modified version of an earlier model of the Invacare XPO2 POC that is
currently listed in Special Federal Aviation Regulation 106, "Rules for Use of Portable
Oxygen Concentrator Systems on Board Aircraft"(SFAR 106) and approved for use on
board aircraft. The modified version of the Invacare XPO2 POC for which you seek
approval has a maximum operating pressure of less than 21.0 pounds per square inch (psia).
It is powered by multiple sources, including AC or DC power, a captive internal lithium ion
battery pack, and a rechargeable external accessory lithium ion battery pack. Both the
captive internal lithium ion battery pack and the rechargeable external accessory lithium ion
battery pack have a Watt-hour (Wh) rating of 83.5 (2.9 ampere-hour (Ah) x 3.6 volts (V) x 8
cells). Both the captive internal and the rechargeable external accessory lithium ion battery
packs meet the appropriate testing requirements of the United Nations Manual of Tests and
Criteria, and both battery packs are packaged in a manner to prevent short circuits. You ask
whether the modified version of the Invacare XPO2 POC is authorized under the HMR to be
carried on board an aircraft.
Based on the information provided in your letter, the modified version of the Invacare XPO2
POC is not subject to the HMR as a Division 2.2 non-flammable gas, the captive internal
and the rechargeable external accessory lithium ion battery packs used to power the device

<<<PAGE 2>>>

conform to § 175.10(a)(18), and the POC contains no other hazardous materials. Therefore,
in accordance with HMR § 175.10(a)(18), the modified version of the Invacare XPO, POC
is authorized to be carried on board an aircraft by passengers or crew members.
Please note that notwithstanding the passenger exception in § 175.10(a)(18) of the HMR,
the provisions of SFAR 106 apply and are under the purview of the FAA. This response
satisfies only one requirement in the FAA approval process before a POC may be carried
and operated on board an aircraft. You may contact Ms. DK Deaderick in FAA's Flight
Standards Service at (202) 267-7480 for questions regarding FAA's approval process.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Duaned. The
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

<<<PAGE 3>>>

DOTARSPA/ OHMS
UNIT
Yes, you can"
15 JAN -6 PM 3:30
December 30, 2014
U.S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration
Office of Hazardous Materials and Standards
1200 New Jersey Avenue, SE
Washington, D.C. 20590-0001
Dear Sir or Madam,
Invacare Corp. is requesting confirmation from the Pipeline and Hazardous Materials Safety
Administration (PHMSA) that the Invacare® XPO_™M Portable Oxygen Concentrator (XPO2
POC) is not subject to the U.S. Hazardous Materials Regulation (HMR) under HMR 49 CFR
Parts 100-180 after review of all appropriate information.
Introduction
Invacare Corp. manufactures portable oxygen concentrators (POCs) and has marketed the XPO2
POC since receiving 510(k) clearance from the Food and Drug Administration (FDA) on
December 12, 2007. The XPO2 POC is currently allowed to be used onboard aircraft and was
added to SFAR No. 106 published in the Federal Register on January 15, 2009. As part of that
application, Mr. Mazzullo of the U.S. Department of Transportation sent a letter to Invacare
Corp. stating that the Invacare® XPO_T Portable Oxygen Concentrator is not subject to the
HMR. Please refer to Attachment 1 for the Federal Register Notice.
The XPO2 POC continues to provide oxygen by separating oxygen from room air utilizing a
molecular sieve and pressure swing adsorption methodology. The resultant concentrated oxygen
is directed toward an oxygen reservoir for delivery to the patient. The XPO2 device delivers the
oxygen to the patient through the pulse delivery method for maximum effectiveness and
operational time. This means that the subject devices deliver oxygen only when a breath is
detected. If no breath is detected (i.e. the cannula detaches from the device or the patient takes
the cannula off), no oxygen is delivered. This feature of delivering oxygen only when a breath is
detected prevents oxygen saturation of the surrounding area or materials when the cannula is not
connected to the concentrator or the patient. The technological characteristics of the modified
XPO2 POC remains the same as the original XPO2 Portable Oxygen Concentrator listed under
SFAR No. 106. Please refer to Attachment 2 for the finished device drawing.
One Invacare Way P.O. Box 4028
INVACARE CORPORATION
eeranora
Elyria, Ohio 44036-2125 USA

<<<PAGE 4>>>

Yes, you can.
Proposed Modifications
Invacare Corporation has modified the internal and external batteries of the XPO2 device to
improve use duration and to increase the expected lite cycle. In addition, some minor design
changes have also been incorporated for quality improvement purposes only.
Power Source for the Invacare XPО2 POC
The subject device can be powered by an internally captive lithium ion battery pack that is not
customer removable or replaceable, an external AC to DC power adapter, an external DC to DC
power adapter, or an external accessory lithium ion battery pack. This allows for maximum
flexibility and operational time with multiple power sources. Recharging of either the internal or
external accessory batteries is only available with the use of the Invacare supplied AC/DC or
DC/DC power adapters.
The internally captive lithium ion battery pack (see Attachment 3) consists of 8 cylindrical 2.9
amp-hour lithium ion cells with a total lithium equivalent content of 6.36 grams of lithium, and
watt hour rating of 85.3 Whr (see Attachment 4). The internally captive battery pack is not user
accessible and not replaceable by a patient/user. The internally captive mechanism of the subject
devices also prevents any user from generating sparks or short-circuiting as it is not externally
accessible. The battery pack terminals are not exposed to any outside contact by virtue of being
totally integrated into the product.
The external accessory battery module for extended operating time is a self-contained power
accessory for the XPO2 device. The external battery module contains a separate lithium battery
pack that consists of 8 cylindrical 2.9 amp-hour lithium ion cells with a total lithium equivalent
content of 6.36 grams of lithium, and watt hour rating of 85.3 Whr. The lithium battery pack is
not user accessible and is not replaceable by a patient/user. The captive mounting mechanism of
the external battery module also prevents any user from generating sparks or short-circuiting the
lithium battery pack. The battery pack terminals are not exposed to any outside contact as they
are connected to an intervening power switching and charging circuit board that interfaces to the
Invacare XPO2 device. The external battery module connection cable contains a connector that
prevents accidental shorting or generation of sparks during handling or storage. Please refer to
Attachment 5 for the external battery module, external battery pack, circuit board schematic and
external battery module connection cable.
The table below compares the XPO2 POC currently marketed with PHMSA approval in 2008
and the evaluation results of the proposed modification
INVACARE CORPORATION
One Invacare Way P.O. Box 4028
Elyria, Ohio 44036-2125 USA

<<<PAGE 5>>>

PHMSA Special Provision 188 Comparison Table
Invacare XPO2 Portable Oxygen Concentrator
Item
PHMSA Criteria
PHMSA 2008 Approval
Pressure of the oxygen in the
Value
Result
2014 Submittal.
Value..
- Result
Comments
1
PSIA at 20C
device does not exceed 40.6
< 21 PSIA
Pass
< 21 PSIA
Pass
No change
2
more than 1.5 grams of lithium
Lithium cells do not contain
2.6 AH Cell
equivalent content
0.78 LEgram
Pass
2.9 AH Cell
0.87 LEgram
Pass
Slight increase in lithium
content
3
Lithium batteries contain an
aggregate equivalent lithium
8 cells/battery
content of not more than 8g
6.24 L E. grams
Pass
6.96 L E. grams
8 cells
Pass
Slight increase in lithium
content
No other
4
materisl sujbect to the HMR
The device contains no other
hazardous
Pass
hazardous
No other
materials
Pass
No change
The batteries are fully
materials
contained in equipment and
Fully contained
5
packaged in a manner to
preclude sparks or the
protective product
inside of
Fully contained
Pass
inside of
[quantity of heat
generation of a dangerous
enclosure
protective product
Pass
No change
enclosure
L.E. gram = Lithium equivalent grams content

<<<PAGE 6>>>

Yes, you can"
Compliance with RTCA/DO-160G
The Invacare XPO2 POC has successfully undergone testing pursuant to the requirements of
RTCA/DO-160G, Section 21, Category M to demonstrate that the device will not interfere with
an aircraft's electrical, navigation or communication equipment. A summary of the test report is
provided in Attachment 6.
Conclusion
In conclusion, the updated XPO2 device continues to meet the five PHMSA Special Provision
188 criteria. In addition, data show acceptable RTCA DP-160 test results. Based on this
information, Invacare Corp. asks that the PHMSA confirm that the Invacare XPO2 device is not
subject to the U.S. Hazardous Materials Regulation under HMR 49 CFR Parts 100-180.
Invacare has discussed the minor modifications to the XPO2 with the Federal Aviation
Administration (FAA) and submitted the proposed changes with supporting documents to the
agency. Prior to their approval, the FAA has requested that Invacare Corp. obtain a letter from
the PHMSA stating that the XPO2 does not contain hazardous materials.
We would appreciate your timely response. A letter from the PHMSA is all that is needed for
FAA approval. If you have any questions, please contact me by telephone at 706-476-2938 or by
email at carol.vierling@yahoo.com.
Sincerely,
Carol Vierling
Acting RA Manager
One Invacare Way P.O. Box 4028
INVACARE CORPORATION
AAAAANNA
ner ac man
Elyria, Ohio 44036-2125 USA

<<<PAGE 7>>>

2352
Federal Register/ Vol. 74, No. 10/Thursday, January 15, 2009/Rules and Regulations
more about SBREFA on the Internet at
regulations_policies/rulemaking/
our site, http://www.faa.gov/
require the same level of special
hazardous materials. Thus, they do not
performance-based standard for all POC
We continue to pursue the
sbre_act/.
handling as compressed oxygen, and are
safe for use on board aircraft, provided
devices. This process is time-consuming
Authority for This Rulemaking
certain conditions for their use are met.
Federal Register and offer the public a
and we intend to publish a notice in the
regarding aviation safety is found in
The FAA's authority to issue rules
on and use certain POC devices on
SFAR 106 permits passengers to carry
when it is complete. In the meantime,
chance to comment on the proposal
Title 49 of the United States Code (49
board aircraft if the aircraft operator
the authority of the FAA Administrator.
U.S.C.). Subtitle I, Section 106 describes
ensures that the conditions specified in
manufacturers continue to create new
the SFAR for their use are met. The
have requested that their product also
and better POC devices, and several
Subtitle VII, Aviation Programs,
devices initially determined acceptable
agency's authority
describes in more detail the scope of the
2005, were the AirSep Corporation's
for use in SFAR 106, published July 12,
SFAR 106. These new manufacturers
be included as an acceptable device in
final rule pursuant to 49 U.S.C. 44701.
The FAA is authorized to issue this
LifeStyle and the Inogen, Inc.'s Inogen
include Delphi Medical Systems and
One POCs. SFAR 106 was amended on
companies has formally petitioned the
Invacare Corporation. Each of these
authorized to establish regulations and
Under that section, the FAA is
add three additional POC devices,
September 12, 2006 (71 FR 53954) to
submitting documentation of the
FAA for inclusion in SFAR 106 by
minimum standards for other practices,
AirSep Corporation's FreeStyle, SeQual
methods, and procedures the
Technologies' Eclipse, and Repironics
Management System. That
devices to the Federal Docket
commerce and national security.
Administrator finds necessary for air
final rule adds two additional POC
Inc.'s EverGo, to the original SFAR. This
documentation is available at http://
devices, Delphi Medical Systems' RS-
following docket numbers:
www.regulations.gov under the
00400 and Invacare Corporation's
Special Federal Aviation Regulation 106
On July 12, 2005, the FAA published
by a passenger on board an aircraft.
XPO2, that may be carried on and used
2008-0261; and
1. Delphi Medical Systems-FAA-
Portable Oxygen Concentrator Devices
(SFAR 106) entitled, "Use of Certain
Aircraft operators can now offer
2. Invacare Corporation-FAA-2008-
106 is the result of a notice of proposed
On Board Aircraft" (70 FR 40156). SFAR
medical oxygen service as they did
no covered device may contain
As stated in Section 2 of SFAR 106,
can meet certain conditions and allow
before SFAR 106 was enacted, or they
, hazardous materials as determined by
rulemaking (NPRM) the FAA published
the needs of passengers who must travel
in July 2004 (69 FR 42324) to address
passengers to carry on and use one of
necessary), and each device must also
PHMSA (written documentation
the POC devices covered in SFAR 106.
with medical oxygen. Prior to
SFAR 106 is an enabling rule, which
included technical specifications for the
be regulated by the FDA. Each petitioner
means that no aircraft operator is
need of medical oxygen during air
publication of SFAR 106, passengers in
required to allow passengers to operate
devices in their request for approval,
when requesting service. Many aircraft
transportation faced many obstacles
these POC devices on board its aircraft,
along with the required documentation
board. If the aircraft operator allows one
but it may allow them to be operated on
petitioners provided the FAA with the
from PHMSA and the FDA. The
operators did not provide medical
oxygen service aboard flights, and those
of these devices to be carried on board,
required documentation for the
that did often provided service at a price
the conditions in the SFAR must be met.
following POC devices:
Coordinating service between operators
that travelers could not afford.
published, the FAA committed to
When SFAR 106 was originally
1. Delphi Medical Systems', Model
and suppliers at airports was also
establishing a single standard for all
2. Invacare Corporation's, Model
chose not to fly because of these
difficult, and passengers frequently
not apply to specific manufacturers and
POC devices so that regulations would
models of devices. Whenever possible,
New medical oxygen technologies
performance-based standards rather
the FAA tries to regulate by creating
include the Delphi Medical Systems'
This amendment to SFAR 106 will
approved by the Food and Drug
Administration (FDA) reduce the risks
manufacturer. In the case of SFAR 106,
than approving specific devices by
RS-00400 and Invacare Corporation's
authorized for use in air commerce. The
XPO2 devices in the list of POC devices
typically associated with compressed
oxygen and provide a safe alternative for both the passenger and the aircraft
the quickest and easiest way to serve
FAA has reviewed each individual
passengers who need oxygen therapy.
Several manulacturers have developed
devices determined to be acceptable by
operator was to allow the use of the
provided by the two manufacturers.
device and accepted the documentation
(POC) devices that work by separating
small portable oxygen concentrator
temporary regulation. As we stated in
the FAA in SFAR 106 in a special,
provided to the manufacturer by
That documentation includes letters
contained in ambient air and dispensing
oxygen from nitrogen and other gases
that established SFAR 106, "while we
the preamble discussion of the final rule
PHMSA and the FDA affirming the
requisites stated in SFAR 106.
status of each device as it pertains to the
it in concentrated form to the user with
an oxygen concentration of about 90%.
are committed to developing a
The POC devices operate using either
performance-based standard for all
safety standards and the PHMSA
After reviewing the applicable FDA
rechargeable batteries or, if the aircraft
future POC devices, we do not want to
operator obtains approval from the FAA,
have the effect of stifling new
prematurely develop standards that
determined by the FAA to be acceptable
findings, these two devices were
aircraft electrical power.
In addition, the Pipeline and
We developed and published SFAR 106
technology of which we are unaware."
for use in air commerce.
Administration (PHMSA) has
Hazardous Materials Safetv
Good Cause for Adoption of This Final
not fly could do so with an affordable
so that passengers who otherwise could
Rule Without Notice and Comment
determined that the POC devices
covered by this amendment are not
alternative to what existed before SFAR
published on July 12, 2005. We stated
As stated above, SFAR 106 was
106 was published.
in the preamble of that final rule that

<<<PAGE 8>>>

QTY.
24148300
1148300
-( .03)
PART NO.
TO DO WORE DEIGNED OR FURIED BY USE ICE
OHIO
DO NOT SCALE THIS DRAWING
1. TORQUE SCREWS (ITEMS 4 & 5) TO 3 IN-LBS.
2. PRIOR TO APPLYING SEAL (ITEM 7) CLEAN
SURFACES TO WHICH SEAL WILL ADHERE
THOROGHLY WITH ALCOHOL WIPES).
3. REMOVE PROTECTIVE COVER/FILM PRIOR
4. INSTALL FERRITE (ITEM 8) ON RED AND BLACK
= CRITICAL QUALITY ATTRIBUTE
• = KEY CHARACTERISTIC IDENTIFICATION
DESCRIPTION
ASM, REAR XPO2
ASM, FRONT XPO2
ASM, BATTERY PACK INTERNAL XP02
SCREW, 6-19 X .75 TORX PAN HD PLASTITE
SCREW, 6-19 X .50 TORX PAN HD PLASTITE
O-RING, 114 ID X .070
SEAL/NOTICE, XPO2
FERRITE, SNAPON
ASM, CONCENTRATOR XPO2
INVACARE CORP. ELYRIA
SEAL/NOTICE TO BE APPLIED TO
ASSEMBLED UNIT, POSITIONED
AS SHOWN. SEE NOTE 2.
TO INSTALLING BATTERY,
WIRE OF BATTERY (ITEM 3).
PART DESCR.PIION:
NOTES:
DATE: 13/16/07
PART NO.
1151575
1184860
1183927
1151831
1151560
1148328
1151839
1147000
NOT SHOWN
ITEM NO
MATERIAL NO.
MATERIAL DESCRIPTION:
ANT PERPO
SCALE 1:2
OPAWN BY: HODOS
PRE-RELEASE
DESIGN ENGR/Date:
MFG/SO ENGR/Bate:
QUALITY/Date:
xx/xx/xx/
3/14/14
0/7/11
01/27/11
OATE
SEE NOTE 3-
REVISION
00. 2/25/14 SW 1184860 WAS 1151580; 1183927 WAS 1148283; REM 1159909; FLIPPED BATTERY UP IN GRAPHICS
F 3. THE OXYGEN GAS MUST MEET THE REQUIREMENTS OF USP 93 EXCEPT FOR THE OXYGEN
01. 3/10/14 SW REV SPEC. NOTE 2; ADDED SPEC. NOTE 3: REV NOTES 2 AND 4
2 OXYGEN VETED SURFACES ARETO BE BIOCOMPATIBLE.
F 1321003 PENDING OUTCOME OF PRELIM CHANGES
1121004 | REV; ADDED 1147000 QTY!: ADDED NOTE 4
02. 7/2/14 SW REV CONTROL PANEL GRAPHICS
D 1121049 REVISION LEVEL RELEASED IN ERROR
1421004 ADDED SPECIFICATIONS
REVISIONS: (1321003)
SPECIFICATIONS:

<<<PAGE 9>>>

1183%27
1183927
SIGNATURE ON FILE
SEE DISTRIBUTION #038
D>= CRITICAL QUALTY ATTRIBUTE
=KEY CHARACTERISTIC IDENIFICATION
ASIM, BATTERY PACK
INTERNAL XP02
INVACARE CORP.
PRE-RELEASE
DESIGN ENGR/Date:
MFG/8Q ENAR/Date:
QUALITY/Date:
-de GET
Stion beltery (4s2P) w/ shrink sieeve & safety circuit wi fuel gauge based on TI# BO20Z95.
- Stardovere ver cure disharge protein 75 AMPS miscond ela
- First tier over cureat rechare pract 2 a AMPS 2 second delay).
• Shan circuit condition will be sel at 25 Amps for 549 Micro seconds
compliant
permanent text and graphics with tamper resistant adhesive backing.
0 XXXXX = sequential assembly starting at 00001 beginning each month
• The phrase "Lithium lon" accompanied by electrical specs and
(1 sec delay, resume 4.1 +/-0:05V)
1. Cell is approved according to UL1642 and IEC62133
-Min state of charge: 30%. Place battery in "Shut Down" mode
• Overdischarge detection: 2.7+/-0.05V
Ambiant Conditions/ Temp range:
10 fo 60 đeg C
25 to 70 deo C
4. Battery pack must meet all IATA requirements
Cabel io be of Polypropylene material and marked with
Do Not Expose to High Temperatures (140F / 60C)
• PCM: Vecture # VC4126. - Thermistor: 10K ohm
• Rated Capacity: 5500mAh min., 5800mAh typical
Charging Method: Constant current+constant voltage
Label itormation to include at a minimum:
5. Wall-hour rating of 83.5Whr
Label Requiremants
• invacare and Mfos P/N's
• Name and focation of assembler
• Serial number formatted MMYY-XXXXX
• MMYY= manth / year of assembly
• The phrase "Lithium Ion Battery" bolded
- Max charga voltage: 16.80V (+/-0.2V)
series/parallel info
• Watt hour rating
• Cell Manufacturer P/N
• WERE ANNEX IV symbol
• The phrases
• Do Not Incinerate
• Do Not Disassemble
• Do Not Short Terminals
• Current Software Revision
- Cell: Panasonic NCR18650
Max continuous charge current: 3A
Rec charge cutoff: 160mA or by time 4h
Max continuous discharge current: 6A
-Internal Impedance: Approx. 180mOhm
-Exp. Life cycle: >300 cycles>70% of initial cap.
• Warning symbol
-Nominal Voltage: 14,4V
Rec. discharge cutoff: 12V
-Thermostat operating temperature:
Opening temp. (off): 77°C =5°C
Closing temp. (on): 45°C Appox.
Charge retention / storage (%)
• 1 year 0-20 to +20 C > 70%%
3 months @ -20 to +45 C > 70%
Humidity: 632220% RHC > 70%
Environmental and Satety
2. Battery assemblv is RoHS
3. ELC of assembly = 6.96g
Differential: Approx 6°C
Charge
• Discharge
• Weight: 410g
UL1061
U1.1061
UL1061
UL1061
1183927
8. 740Ł10
AWG20 UL1061
AWG22
AWG22
AWG22
AWG20
...÷
2×3
SPECIFICATION LABEL
SEE "TABC CONIENTS*-
Yellow
Green
White
Black
Red
A Label auto conse r er cloned y negat grumber:.
IE: 0310-00001 = March, 2010 - First pack of that P/N shipped.
Connector Molex 39-01-2060
154: 5
* 1335:10
Software Version: 05
Batt -
NC
T Batt +
202252222
À22s fo
Pin 4
Pin 5
[Pin 6

<<<PAGE 10>>>

Panasonic
ideas for le
NCR-18650
LITHIUM-ION / NNP + HRL TECHNOLOGY
Panasonic is one of the leading Lithium-lon battery manufacturers in the world. A perfect combination of high energy density, safely and long
life shows what is possible with this battery technology. A continuous co-development with electronical companies all over the world has led to
people's safety. On the top of this we have invented our so called NNP technology which gives us the possibility to achieve eminently high battery
outstandingly good results. Panasonic especially focuses on enhancing safety technologies such as PSS and HRL in order to always guarantee
capacities. Excellent battery safety on one hand, and superior battery performance on the other: this is what Panasonic stands for.
1 Positive pole
2 PTC (positive
6 Cathode
temperature
7 Anode
3 Gasket
coefficient device)
9 Separator
8 Negative pole (cell can]
5 insulator
4 Collector
10 CID (current interrupt
•3:
11 Exhaust gas hole
ENNETECHNOLOGY!
ubiquitous society. As cordless devices become more sophisticated and powerful, they require more robust battery cells. Panasonic has
Li-lan battery cells have become indispensable as a power source for
cordless equipment, such as laptops, that supports a
as its material and processing technology which prevents deformation of the alloy-based negative electrode when subjected to repeated charge
responded to these challenges with the new battery cells, employing its unique high capacity nickel based positive electrode technology as well
and discharge. This new battery technology is called Nickel Oxide based New Platform.*
Characteristics of the new Panasonic
AND SAFETY OF CATHODE MATERIAL
COMPARISON BETWEEN CAPACITY
NNP Technology:
→ Superior cycle life performance
→ The new nickel positive electrode exceeds regarding durability in actual use
→ High energy density contributes to downsizing and weight reduction
More Safety
→ Excellent shelf-life due to low self-discharge performance
and charge retention
NNP based
SHRL TECHNOLOGY
High Capacity
As a power source for mobite and digital equipment essential for a ubiquitous networking society, demand for Lithium-lon batteries has
sophisticated and feature-laden, they require more robust and safer batteries. Increasing energy-density, however, raises the risk of
grown fast. As such equipment including notebaok PCs, mobile phones, medical equipment and power-tools become more powerful,
Lithium-lon batteries significantly. This heat resistance layer consist of an insulating metal oxide on the surface of the electrodes which leads
overheating and igniting due to short-circuiting. Panasonic employs the HRL (Heat Resistance Layer) Technology to improve the safety of
the battery not to overheat even if a short-circuit occurs.
Safety is the base for everything. Higher Energy can be established based on safety technology.
HRL Technology
Existing Technology
HAL
Separator
+ Material
- Material
Panasonic
Quality is ou

<<<PAGE 11>>>

Panasonic
Bartene
LITHIUM ION
Features & Benefits
Dimensions
• High energy density and voltage
• Long stable power with flat discharge voltage
Max 18.6 mm
• Ideal for portable communications, portable
computing and robotics
Specifications
Panasonic
Capacity:
2.9Ah Typical
(Charge: CVCC, 4.2V, max.
(Discharge: CC, 550mA, 2.5V
1925mA, 50mA cutoff, 25°C)
cutoff, 25°C)
Max 65.2 mm
Nominal Voltage: 3.6V
Weight:
Approximately 44.5g
Charge Characteristics
Discharge Characteristics
5.0
Charge Condition:
3200
5.0
4.5
2900
Charge Condition: CVCC
isonarce Condition: CUNSTANT CURRENT 25V cong" at 15
40370:192041, 50041
c# 3: 25 C
= 2.0
VOLTACE
2400
4.5
3000 T
E 1.0
201t(8500mAI
1.012 (2760m4)
0.211;530ms)
GAROCITY
2.5
400
7.0
2.0
0.0
0.5
1.0
1.5
2.0
TIME (hour)
25
3.0
3.5
as°
2.5
500
1000
DISCHARGE CAPACITY (mAn)
1500
2000
2500
3000
Discharge Characteristics
Cycle Life Characteristics (25°C)
_ITHIUMION/NCR18850/6.11V1 | Copyright © 2011 Panasonic Corporation of Amerca. All Rights Resarved.
5.0
Discharne Condition: (r
Charge Condition: LEV
1CH CH(760HA
3200
4.5
2000
60°C
2400
VOLTAGE (V)
4.0
3.5
tic
CAPACITY (mAh)
=2300 mAk
79%0
1200
RemAining CapACiTY
3.0
-10°C
800
o'c
400
Charge Condition: CYCO: 270x07: 2/lex07: 4) 5:
2.5
800
1200
2000
2400
2ano
Charge/Discharge Rest Time: 29r9224
DISCHARGE CAPACITY (mAh)
100
CYCLE NUMBER
200
300
The data in this document is for descriptive purposes only and is not intended to make or imply any guarantee or warranty.
Panasonic
For more information on how Panasonic can assist you with your battery power solution needs cal 877-726-2228,
visit www.panasonic.com/industrial/batteries-oem or e-mail oembatteries@us.panasonic.com

<<<PAGE 12>>>

NCR-18650
LITHIUM-ION / NNP + HRL TECHNOLOGY
Max. 18,6
5.0 г
CHARGE CONDITION: CVCC*, 4,2V max. 0.7l (1925mA), 50m4 cul-off at 25deg.C
4.5
DISCHARGE CONDITIGN: CC**, 2.5V cut-off at 25deg.C
4.0
(+)
VOLTAGE M
2.0ft (5500mA) 1.0(2750mA) 0.21 (550mA)
3.0
Max. 65.2
2.5
500
1000
1500
2000
2500
3000
DISCHARGE CAPACITY [mAh]
50
CHARGE CONDITION: CVCC*?, 4.ZV max. 0.7it [1925mA), 50m4 cut-off al 2Sdeg.C
(-)
4,5
DISCHARGE CONDITION: CC*:, 1.0kt (2750mA), 2.5V cut-off at various temperature
60deg.C
SPECIFICATIONS
4.0
45deg.c
Nominal voltage (VI
Madel Number
VOLTAGE M
25deg.c
3.6
Nominal capacity*' - Minimum (mAh)
Nominal capacity*! - Typical (mAh)
2,750
Dimensions - Diameter (mm)
2,900
3.0
-10deg.c
Dimensions - Height (mm)
max. 18.6
Odeg.C
Approx. Weight (g)
max. 65.2
2.5
500
1000
1500
2000
2500
3000
45
DISCHARGE CAPACITY (mAn)
5.0
(1925mA), 50mA cut-off at 25deg.c
CHARGE CONDITION: CVCC*!, 4.2V max. O.7lt
$ 280D
3000
4.5
2400
200D
2500
1.0
(VOLTAGE
1600
(mAh]
z0u0
CURRENT [mA]
CAPACITY(mAh)
= 2100 mAh
oR 12 %
CAPACITY
CAPACITY
3.0
- * CURRENT
800
1000
RemAiNiNg CApACiTY
400
500
CHARGE CONDITION: CVCC**. 4.2V max, 0.7lt [1925mAl, 50mA cut-oft at 25deg.C
CHARGE / DISCHARGE REST TIME: 20min.
DISCHARGE CONDITION: CC**. 1.0tt 12750mAl, 2.5V cut-off at 25deg.C
25%
0.5
10
TIME (hour)
1.5
2.0
2.5
0
100
CYCLE NUMBER
200
300
40D
500
We sauna to lo depor singie tell business or accept orders irom consumers. We design Lihum-lon battery Backs incluting a sul able sately urit
your local Panasonic Sales Office. In order to avoid a lack of supply please check the battery availability with your Panasonic sales team before design-in
device based on the technical specification of the customer. Due to the need for careful review when selecting Lithium-Ion battery solutions please contact
Panasonic
Panasonic Industrial Europe GmbH | Winsbergring 15 | 22525 Hamburg | Website: http://industrial.panasonic.com/eu

<<<PAGE 13>>>

PATKO.
1184859
QIY.
T PART NO.
1184859
D = CRITICAL QUALITY ATTRIBUTE
* = KEY CHARACTERISTIC IDENTIFICATION
ASM. EXTERNAL
BATTERY XPO2
INVACARE CORP. EYRA
DESCRIPTION
SHELL, EXTERNAL BATTERY FRONT XPO2
SHELL, EXTERNAL BATTERY REAR XPO2
SWITCH, MEMBRANE EXTERNAL BATTERY XPO2
BRACE, EXTERNAL BATTERY XPO2
ASM, PCB EXTERNAL BATTERY XPO2
BATTERY PACK, EXTERNAL BATTERY XPO2
SCREW. 6-19 X.50 TORX PAN HD PLASTITE
LABEL, WARNING XPO2 SUPPLEMENTAL BATTERY
FOAM, OPEN CELL 1/4 X 1 X 2 W/ PSA
LABEL, SERIAL NUMBER (SANFORD RESPIRATORY)
ASM, CABLE EXTERNAL BATIERY XPO2
MFG REQUIREMENTS, ESD
(1.36)
LABEL LOCATION VIEWS
CAE: 4/16/13
1148322
1148323
1148321
1148324
1180060
1184130
1151560
1184854
1152766
1153701
1180059
1182067
ITEM NO. PART NO.I
MAMML NG
SATESAL CESCKPSION
OZAUN BY: 8. KUSHNER
11
Aretc.
SOALE: 1:1
(6.25)
PEcanon"
04E 199
V7 Cx 0N2.|DN0. TAGN:
AND ALGN PER DIMENSIONS ABOVE
ANY CONNECTOR FACING UP
NOTES:

<<<PAGE 14>>>

1184130
(6)
1184130
Wiza slagpe
M vpr
Ma! : !b:
Connector Hsg
IST# XIP-
I'ciminat
SXI1-0011-P0.6
Wire
26 awg Ut.1007
O.RN. 10-3-14
ELYPIA
OHIO
D>= CRITICAL QUALITY ATTRIBUTE
= KEY CHARACTERISTIC IDENTIFICATION
BATTERY PACK, EXTERNAL
BATTERY XPO2
e tomto omr eupa,
.te lo.s.?.
of U3.54h
INVACARE CORP.
2092.3
,Lm82 4 236. F - 10
AT/ 10-10904060 15
PRE MELENSE
DESIGN ENGR/B8t8:
MEG/SQ ENCR/Bate:
QUALIYV/DAte:
659/11/21
i JST
ХHP-2
:38893
"hew!
1184130
43711 -
,. IONI
10515
1815
A 132+1
TI!
HIROSE DF3-5S-2C
HIROSE DF13-8S-1.251:
8 41:1
040 2, M RESI WONI FROM 20510 :11
142
4 211
11 -52•
1g 'gri
.. s.11
o XXx = sequenial assembly starling oil 00001 beginning each month
: 12%
ctesoveds coend dockag@ polecon •66 AMdSf ondd debay
permanent text and graphics wilh lamper resistan adhesive backing.
Ihe: pistes: "i allam tori" es componied by eleciricol specs and
are dee boves conend edoarkne protes bonr6 AMIS second ebecky)
ic ...
Labet fo boa Poly oplene maleriol ond marked with
o Do Nol Expose lo High Tomperalures (140F / 60C)
Latae ploppento dos ay torle ol a minimum:
tad contenh(4 39x1 00)
Name and localion of assembler
Seral number formolled MMYY-XXXXX
o MMYY= monih / yeor of assembly
(l sr sekery mesone s0 ? gov!
1'x4,375" SPI• BE ATION LABEL: SEE "LABEL CONTENTS"
0303-3a10
1:oa0 UF13-63 1.296
• The phrase "Lithium lon Baltery" bolded
TEVE CHePR MASPA!
Woll taar costun;
Ce Mesuts bang Dt
• WELE ANNEX IV symbol
o Do Not incinerale
o Do Noi Disassemble
o Do Not Short Terminals
Curren i sollwore Revision
- The phrases
Cell Prolection:

<<<PAGE 15>>>

1185335
1185335
>= CRITICAL QUALITY ATTRIBUTE
= KEY CHARACTERISTIC IDENTIFICATION
PRIOSCHEMATIC, EXTERNAL
BATTERY XPO2
INVACARE CORP, ORA ATIS
SIGNATURE ON FILE
SEE DISTRIBUTION #032
DAE 11/21/13
Axа72E
ESSP
20/0-P5
PRE-RELEASE
DESIGN ENGR/Date:
MFG/SO ENGR/Date:
QUALITY/Bate:
MATEHA: BESCHPRUK
2000
HIND
AME PRICI
SCME: 1.375:1
DRAWN BY S. WEINMAN
ONE
2-70
:8: sz
DE: 52
hotten i
alie
CANNO

<<<PAGE 16>>>

1180059
V+
V+
SECTION A-A
1180059
HIROSE DF3-4S-2C
RED
BLACK
BLUE
WHITE
0.24
ELYRIA
2X .041.02
2X .075‡.020
› = CRITICAL QUALITY ATTRIBUTE
= KEY CHARACTERISTIC IDENTIFICATION
PIN 1
PIN 2
PIN 3
PIN 4
ASM, CABLE EXTERNAL
BATTERY XPO2
INVACARE CORP.
.35+.02
Ø.391.02
*. Ф.10t.05
.53+.02
0p00n2
2/20|2013
Ø.22+.05
BERT
1.85+ 50
Dom Play 12414
DESIGN ENGA/Date: HUza Ahmad
A 4.727.50
PRE-RELEASE
...10+.02
01. 03/20/12 H - ADDED SECTION A-A AND MOUNTING PANEL GAP (.102) DIMENSION,
07. 06/18/13 8K - CHG DC# WAS 1221019: UPDATE TITLE BLOCK AND PRE-RELEASE STAMP
A 1.97+.25 -
CHGED VENDOR AND ADDED VENDOR P/N
A I. MANUFACTURER: PROTEK POWER, P/N 120314-O1R
OS. 07/07/12 TH - CHANGE SPECIFCATION TO MATCH PROTEK PRINT
03 04/10/12 TH - ADDED PIN OUT COLOR CODE TABLE
04, 05/09/12 JMK. CANCEL. 1221025, CHANGE TO 1221019
00. 03/06/12 TH - CREATED DRAWING
02. 03/29/12 TH - CORRECTED MFG P/N
06. 08/07/12 8K - CHG DIM 10:.02 WAS .102
DF3-4S-2C (PITCH 2mm)
REVISIONS (1321003):
08. 2/20/14 SW REV DESC.
A HIROSE SOCKET
HIROSE CONTACT
DF3-22SCF
WITH
NOTES:

<<<PAGE 17>>>

COC14061-040814FA
F2 Labs
16740 Peters Road
Middlefield, Ohio 44062
United States of America
www.f2labs.com
EMC TEST REPORT
Manufacturer:
Invacare Corporation
Elyria, Ohio 44036
One Invacare Way
United States of America
Product:
Portable Oxygen Concentrator
Models:
XPO100B*; XPO100
*Denotes actual model tested. Refer to Section 2.1 of this Test
Report for more details.
Testing Commenced:
Apr. 4, 2014
Testing Ended:
Apr. 4, 2014
Summary of Test Results: Page 4
Deviations (if applicable):
N/A
Standards:
RTCA DO-160G - Environmental Conditions and Test Procedures for Airborne
Equipment Testing Section 21, Category M
Report Number F2LQ6037-06E
012414
Page 1 of 24
Issue Date: Apr 23. 2014

<<<PAGE 18>>>

COC14061-040814FA
Order Number: F2LQ6037
Client: Invacare Corporation
Models: XPO100B & XPO100
for hsupe....
Evaluation Conducted by:
Joe Knepper, EMC Proj. Eng.
Report Reviewed by:
Ken Littell, EMC Tech. Mgr.
26501 Ridge Road
F2 Labs
F2 Labs
Damascus, MD 20872
16740 Peters Road
Fax 301.253.5179
Ph 301.253.4500
Ph 440.632.5541
Middlefield, OH 44062
Fax 440.632.5542
onsent of F2 Labs. The results in this report apply only to the equipment tester
his test report may be reproduced in full; partial reproduction only may be made with the writte
maintenance fia tar
041014
Report Number: F2LQ6037-066
Page 2 of 24
Issue Date: Apr. 23 2014

<<<PAGE 19>>>

COC14061-040814FA
Order Number: F2LQ6037
Client: Invacare Corporation
Models: XPO100B & XPO100
TABLE OF CONTENTS
1.0
ADMINISTRATIVE DATA
1.1
1.2
Management of Test Sample
Abbreviations and Acronyms
1.3
Document History
LIST OF EUT, ACCESSORIES AND TEST EQUIPMENT
Equipment Under Test
Accessories
Cables
MODE OF OPERATION
METHOD OF MONITORING
REQUIRED MODIFICATIONS
RADIATED EMISSIONS TEST
Radiated Emissions Test Procedure
Radiated Emissions Test Data Sheet
6.3
Photographs) of Radiated Emissions Test Setup
7.0
CONDUCTED EMISSIONS TEST
7.1
7.2
Conducted Emissions Test Data Sheet
Conducted Emissions Test Procedure
7.3
Photographs) of Conducted Emissions Test Setup
Report Number F2LQ6037-06E
Page 3 of 24
Issue Date: Apr. 23.2014

<<<PAGE 20>>>

•
COC14061-040814FA
Order Number: F2LQ6037
Client: Invacare Corporation
Modeis: XPO100B & XPO100
GENERAL REPORT SUMMARY
This electromagnetic emission test report was generated by F2 Labs. The test report is based
on testing performed by F2 Labs personnel according to the measurement procedures
described in the test specifications given below and in the Test Procedures section of this
report.
SECTION
TEST
RESULTS
Radiated Emissions:
6
Internal Battery Power
Pass
External Power Supply
Pass
7
Conducted Emissions:
External AC/DC Power Supply
Pass
Note: Pass/Fail criteria are based upon the following condition: Where the results are
compared to published test standard or manufacturer specified limits, the PASS or FAIL
opinion is considered without applying the laboratory stated measurement uncertainty.
Reports noted as a revision replace all previously issued reports and/or antecedent report
revisions issued under this job number.
Report Number: F2LQ6037-06E
0410:4
Page 4 of 24
Issue Date: Apr. 23. 2014
- **truncated:** false
- **body characters:** 36289