{"operation":"document","citation":"16-0022","title":"EMC Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-03-07","effective_on":null,"summary":"16-0022 response to EMC Corporation concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/69436/160022.pdf","body":"<<<PAGE 1>>>\n\nEMC Corporation\n2421 Mission College Boulevard\nSanta Clara, CA 95054\nReference No. 16-0022\nDear Mr. Wilcox:\nThis letter is in response to your January 12, 2016, e-mail and subsequent conversation\nwith staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). You reference a letter of interpretation previously issued to you under Reference\nNo. 12-0137 in November 2012, addressing testing requirements in the United Nations (UN)\nManual of Tests and Criteria (MTC) for a completed system that consisted of multiple lithium\nion battery packs connected to a single printed circuit board used to power a memory card.\nBased on the information provided, we stated in the 2012 letter that the final connected system\ndid not appear to be a battery assembly as described in UN MTC 38.3.3(f). Therefore, it was the\nopinion of this Office at that time that a completed connected system containing lithium ion\nbattery packs as described was not required to be tested in accordance with part III sub-section\n38.3 of the UN MTC provided the lithium ion battery packs themselves had successfully passed\nthe tests. In this follow-up 2016 letter, you ask questions regarding the classification and testing\nof lithium battery assemblies assembled from your battery packs electrically connected to a\nprinted circuit board when shipped as replacement spares. Based on the supplemental\ninformation provided in this recent letter and consistent with amendments to the MTC and HMR,\nit is now the opinion of this Office that the battery configuration used in your systems consisting\nof battery packs connected to a single printed circuit board with a single output cable would be\nconsidered a battery assembly.\nWe have paraphrased and answered your questions as follows:\nQ1. Are the battery assemblies subject to testing if the lithium ion battery packs contained\nwithin the assemblies have successfully passed the tests prescribed in section 38.3 of the\nUN MTC?\nA1.\nThe answer is yes. Section 173.185(a) states that each lithium cell or battery must be of\nthe type proven to meet the criteria in part III, sub-section 38.3 of the UN MTC. Battery\nassemblies, which have a Watt-hour (Wh) rating of not more than 6,200 Wh, must be\ntested in accordance with UN MTC 38.3.3(f). Although the lithium ion battery packs\nhave passed all applicable tests, if they are electrically connected to form a battery\nassembly, then the battery assembly must be tested in accordance with UN MTC\n38.3.3(f).\n\n<<<PAGE 2>>>\n\nQL.\nas \"UN3480, Lithium ion batteries\" or \"UN3481, Lithium ion batteries contained in\nequipment\"?\nA2.\nLithium ion batteries not contained in or packed with the equipment for which they will\nprovide electrical power must be transported as \"UN3480, Lithium ion batteries\" (see\n§ 173.185). In this scenario, the battery assembly powers the memory card. Thus,\nbattery assemblies attached only to a printed circuit board, but not to a memory card,\nwould be classified as \"UN3480, Lithium ion batteries.\"\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDiane A.777\n1\nDuane A. Pfund\nInternational Standards Coordinator\nStandards and Rulemaking Division","truncated":false,"body_characters":3232}