16-0093 - Broadcom Limited — Hazardous Materials Safety Interpretation | Regulus

Page 1Broadcom Limited 4165 Shackleford Road Norcross, GA 30093 Reference No. 16-0093 Dear Mr. Laudano: This letter is in response to your May 24, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to proper shipping names. Specifically, you ask for the appropriate proper shipping name for a Broadcom Cache Backup Unit (CBU) that contains a lithium ion cell electrically connected to a Printed Circuit Board Assembly (PCBA). You further state that the CBU provides power to RAID controller memory in the event of a power loss. As specified in § 173.22 of the HMR, it is the shipper's responsibility to properly class and package a hazardous material. While this Office does not normally perform this function, we are able to provide guidance. Based on the information you provide in your emails and the requirements of the HMR, it is the opinion of this Office that the CBU in your scenario is most appropriately described as "UN3480, Lithium ion batteries." The introductory paragraph to § 173.185 of the HMR defines equipment as " •...the device or apparatus for which the lithium cells or batteries will provide electrical power for its operation." According to your description, the CBU provides power to the RAID controller memory. As such, when shipped separate from the RAID controller memory, the CBU does not meet the definition for "UN3481, Lithium ion batteries contained in equipment." I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Duan A.1Xa Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Please log this request for a letter of interp. Kevin From: Richard Laudano [mailto:richard.laudano@broadcom.com] Sent: Tuesday, May 24, 2016 2:18 PM To: Leary, Kevin (PHMSA) Cc: Like Xie; Ismat Jahan; Tyson Crist Subject: Broadcom Review Request for Packed With or In Equipment Mr. Leary, Your name was passed along to me from Like Xie of Inventus (formally Palladium) as a potential source to assist in getting a review of our question whether out our use of Lithium-lon cell can be considered UN3481 or Packed With or In Equipment. Our feedback so far has resulted in an agreement form my contacts at IATA and a no decision (stating that the definition of equipment is too vague) from Shanghai Chemical Research Institute. I am hoping that you can guide me in getting a review of my equipment to determine if it does meet the standard of UN3481. Can you review or forward to someone who can review the attached documents from Broadcom and Intel (a Broadcom customer who reships the equipment) to determine how we can classify the equipment? I apprciate any assistance you can provide in this effort. Please contact me if you have any questions or need any additional information. Thanks, Richard Laudano Commodity Engineer Broadcom Limited Phone: 678-728-1338 Mobile: 678-294-3572 richard.laudano@broadcom.com www.broadcom.com#

Page 4• Broadcom has continued working with IATA and suppliers to moni • Recently Broadcom focused its efforts to understand the interface • Since the battery cell in the pack has no external interface Broado has changed from a lithium battery shipment (UN3480) to a lithiur shipment with or in equipment (UN3481), Packing Instruction 966 • In order to more accurately describe the function the assembly, fo it is more appropriate to call it a cache memory back-up unit (CBL • The volumetric energy density of the CBU is relatively low betwee and impact to shipping methods. / Broadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved. battery backup unit (BBU) Broadcom Position cell in our application. Wh/l.#

Page 5Broadcom's Cache Backup Unit (CBU) is designed to provide backı If a power failure is detected, the cache memory power source is sv primary to backup system power using controls resident on the RAI During power failure, the battery cell in the CBU supplies power to t regulation circuit contain in or attached to the module. The CBU's re circuit creates all necessary voltage rails in order to provide the req maintain data in the cache long enough until system power is restor the RAID controller memory in the event of power loss. Broadcom CBU Function Details Broadcom Limited Proprietary and Confidential. @2016 Broadcom Limited. All rights reserved. board and CBU.#

Page 6Justification for Changing to Packed With or In Equip For the purposes of this packing instruction, IATA defines "equipme device or apparatus for which the lithium cells or batteries will provi From the SP188(i) document: As used in this special provision "eqi means apparatus for which the lithium cells or batteries will provide The Li-lon cell in the equipment only provides power to the apparat which contains the charger chip) and the cell's interface (input or ol not exit the PCBA. It looks like this does meet the current definition For Broadcom's application the lithium cell only provides electrical p apparatus (PCBA which contains the charger chip) that is either inte the pack or connected via a short wire harness and has no direct ex All rights reserved. Broadcom Limited Proprietary and Confidential. © 2016 Broadcom Limited. power for its operation. power for its operation. (UN3481) interface.#

Page 7Cache Backu Unit 1.5V or 1.8V DRAM RAID Controller Car BACKUP CELL CACHE - MEMORY 1.5V or 1.8V DS273: SWITCH MODE ICCCV: POWER MANAGEMENT SWITCHING REGULATOR POWER VReg 12V from PCle Bus Battery Cell Broadcom CBU Block Diagram Broadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved. Green - Power during Blue - Power during normal operation back up operation#

Page 8BOTTOM SIDE 1L1.2024.5 Broadcom single cell CBU with integrated charger card Broadcom single cell CBU connected to charger card Broadcom Single Cell CBU Types Pery is Initi manufacturi TOP SIDE Broadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved. Model BAT151P-A#

Page 9From what you say, it sounds like the battery is an integral part of : contained in equipment. If it is separate from the equipment, it she From: YMQ Dangerous Goods [mailto: dangood@iata.org] 33, Route de l'Aeroport, 1215 Geneva 15 Airport, Switzerland From: Richard Laudano [mailto:richard.laudano@broadcom.com Thanks for your feedback. Given the information I provided will thi application where the battery cell has no interface outside of the p guidance and hoped your group could look at my unusual applicatic but need to know if it will provide more information than the PI 96: Sent: Tuesday, May 10, 2016 7:45 AM| To: Richard Laudano; YMQ Dangerous Goods Subject: RE: Packed With or In Equipment? To: YMQ Dangerous Goods <dangood@iata.org> Manager, Dangerous Goods Standards International Air Transport Association Subject: Re: Packed With or In Equipment? www.iata.org/dangerousgoods I hope this helps. Paul Horner Tel: +41 22 770 2045 Fax: +41 22 770 2686 Email: hornerp@iata.org Sent: 10 May, 2016 11:21 AM Richard, Regards Paul Thanks Richard Sent: Mon 5/16/2016 5:18 IATA Agreement of Broadcom Position + 0 From the description of what you have this appears to be lithium ion batteries contained in equipment. As such it is UN 3481, and must meet the applicable parts of Section Il of packing instruction 967. Broadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved. 33, Route de l'Aéroport, 1215 Geneva 15 Airport, Switzerland Lithium Battery Workshop BRUSSELS, BELGIUM 11-13 OCTOBER 2016 RE: Packed With or In Equipment? YMQ Dangerous Goods Richard Laudano dangood@iata.org Asst. Director Cargo Safety & Standards International Air Transport Association Please consider the environment before printing this email David BRENNAN Tel: +41 22 770 2947 Mob: +41 79 505 9495 Fax: +41-22-770-2686 email: brennand@iata.org www.iata.org/dangerousgoods From: Subject: Signed By: Richard. Regards:#

Page 11Lithium Ion Batteries - Shipping By Air experience what's inside™ Owner: Liliana Alonso Date: WW17 16 Deg execution & operations intel) Datacenter Engineering Group#

Page 12The International Air Transport Association (IATA) has recently made (relative in the regulation for transportation of Lithium-lon (Li-lon) batteries that may im As of April 1st, 2016, the new IATA regulations for air transportation pertaining • Standalone batteries not permitted to be shipped in cargo area of passeng • Standalone batteries are permitted to be shipped in cargo area of air freigt • Batteries when contained/installed in equipment are not subject to these re • Batteries packed with the equipment they power are not subject to these re • The definition of what 'equipment' means is not 100% clear • The definition of what 'equipment' means is not 100% clear deliver shipping products to our customers Problem Statement be discharged to <=30% are summarized as follows: Deg execution & operations Datacenter Engineering Group#

Page 13PCSD RAID Batte AXXRSBBU3 AXXRSBBUSS AXXRSBBU4 AXXRSBBU6 AXXRSBBU7 AXXRSBBU7D10 AXXRSBBU7S AXXRSBBU8 AXXRSBBU9 Products Impacted: Impact to Commercial Business as of April 1, 2016 • Current Intel inventory of batteries is at 45%-50% of charge. This charge ‹ • Our battery units are physically installed to a PCB with the charging and n • Batteries in warehouse, disti's, etc. are on ship hold and cannot be shippe when they are built by a third party and then provided to Intel all cases, and are shipped to/from Intel with these connected customers Deg execution & operations Datacenter Engineering Group#

Page 14After analysis by Tiger Team and approval from Hazardous Material Intel Leader Matt Riffey and Regulat Pasternak, current battery inventory in Intel warehouses at 45%-50% of charge should be enabled to be s batteries contained in/with equipment." Team believes this adheres to the both the spirit and letter of the I still regulated and restricted, but this designation can be shipped on passenger aircraft, the SOC is not a f • Enables urgent shipments for NCR that are still held in Intel warehouses to ship directly and immediate • Avoids scrambling to rework (no defined solution yet), and other transportation modes do not meet nee Risk to position: Interpretation of 'equipment' is ambiguous. When these BBU's are installed and activate power loss occurs, the batteries power/use the PCB and cable, but also supply power to the RAID card m (which is not included in the shipping equipment). The memory is on the RAID card, not on the local PCB. ambiguous equipment definition, there is potential for whether Intel is adhering to the letter of the restrictic Action Requested: Inform Intel Legal of the situation and the recommendation above, and and get approv: Follow Up Action Required: RAID team will implement <30% SKU's over coming 2 months, and update all values, in case IATA decides to further restrict ALL batteries to this level. Broadcom has now committed t enable shipping of all current inventory to customers currently backlogged for units. and they have already started needed actions for implementation as planned. move forward with shipping Li-lon BBU's as 'shipping with equipment.' • Immediately resolves the impact on LDT for end customer Position Recommendation: • Avoids rework for current inventory sprit based on tiger team assessments). Deg execution & operations Datacenter Engineering Group Benefits to position:#

Page 15Deg execution & operations BackUp Datacenter Engineering Group#

Page 16Redesig Batte With mill Cells greater than Batteries greater 20 Wh; and than 100 Wh Limit per package: UN3481 PI 966 Section 1 Pax A/C = 5 kg IMP: RLI CAO = 35 kg No Cells 520 Wh; and Batteries ≤100 Wh Limit per package: (not moro than 1 ≤ 2.7 Wh = 2.5kg: or cells > 2.7 Wh ≤ 20 Wh UN3480 PI: 965 Section II IMP: ELI package) = 8 cells; or batteries > 2.7 Wh ≤ 100 Wh = 2 batteries Forbidden on Pax 09/03/2016 Part III Subsection All cells and batteries must be tested in accordance with 38.3 (DGR 3.9.2.6) Passed UN? Yes Lithium Ion Batteries (limited to a maximum of 30% SoC) Colls ≤ 20 Wh; and Batteries 5100 Wh NOTE: Use "IB" 11 package exceeds Section Il Limits and more than 1 package Limit per package: Pax A/C = Forbidden UN3480 PI 965 Section IB IMP: RLI CAO = 10 kg the UN Manual of Tests and Criteria all. Cells greater than 20 Batteries greater Limit per package: Pax A/C = Forbidden Page 5 Wh: and than 100 Wh UN3480 Section IA IMP: RLI CAO = 35 kg PI 965 Colls equal to or less than 20 Wh; Batteries equal to or less than 100 Wh Limit per package: and UN3481 PI 967 Section II Pax A/C = 5 kg IMP: ELI CAO = 5 kg Lithium ton Batteries Contained in Equipment • exceptions exist to the labelling requirements - In. APCS/Cargo Classification Flowchart - Lithium Ion Batteries Deg execution & operations Cells greater than Batteries greater 20 Wh: and than 100 Wh Limit per package: see PI 967 Section I| Datacenter Engineering Group UN3481 PI 967 Section 1 IMP: RLI Pax A/C = 5 kg | CAO = 35 kg#