{"operation":"document","citation":"16-0093","title":"Broadcom Limited — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-05-04","effective_on":null,"summary":"16-0093 response to Broadcom Limited concerning 173.185, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0093.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0093.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0093","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/160093.pdf","body":"<<>>\n\nBroadcom Limited\n4165 Shackleford Road\nNorcross, GA 30093\nReference No. 16-0093\nDear Mr. Laudano:\nThis letter is in response to your May 24, 2016, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to proper shipping names.\nSpecifically, you ask for the appropriate proper shipping name for a Broadcom Cache Backup\nUnit (CBU) that contains a lithium ion cell electrically connected to a Printed Circuit Board\nAssembly (PCBA). You further state that the CBU provides power to RAID controller memory\nin the event of a power loss.\nAs specified in § 173.22 of the HMR, it is the shipper's responsibility to properly class and\npackage a hazardous material. While this Office does not normally perform this function, we are\nable to provide guidance. Based on the information you provide in your emails and the\nrequirements of the HMR, it is the opinion of this Office that the CBU in your scenario is most\nappropriately described as \"UN3480, Lithium ion batteries.\" The introductory paragraph to\n§ 173.185 of the HMR defines equipment as \"\n•...the device or apparatus for which the lithium\ncells or batteries will provide electrical power for its operation.\" According to your description,\nthe CBU provides power to the RAID controller memory. As such, when shipped separate from\nthe RAID controller memory, the CBU does not meet the definition for \"UN3481, Lithium ion\nbatteries contained in equipment.\"\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDuan A.1Xa\nDuane A. Pfund\nInternational Standards Coordinator\nStandards and Rulemaking Division\n\n<<>>\n\nPlease log this request for a letter of interp.\nKevin\nFrom: Richard Laudano [mailto:richard.laudano@broadcom.com]\nSent: Tuesday, May 24, 2016 2:18 PM\nTo: Leary, Kevin (PHMSA)\nCc: Like Xie; Ismat Jahan; Tyson Crist\nSubject: Broadcom Review Request for Packed With or In Equipment\nMr. Leary,\nYour name was passed along to me from Like Xie of Inventus (formally Palladium) as a potential source to assist in\ngetting a review of our question whether out our use of Lithium-lon cell can be considered UN3481 or Packed With or In\nEquipment. Our feedback so far has resulted in an agreement form my contacts at IATA and a no decision (stating that\nthe definition of equipment is too vague) from Shanghai Chemical Research Institute.\nI am hoping that you can guide me in getting a review of my equipment to determine if it does meet the standard of\nUN3481.\nCan you review or forward to someone who can review the attached documents from Broadcom and Intel (a Broadcom\ncustomer who reships the equipment) to determine how we can classify the equipment?\nI apprciate any assistance you can provide in this effort. Please contact me if you have any questions or need any\nadditional information.\nThanks,\nRichard Laudano\nCommodity Engineer\nBroadcom Limited\nPhone: 678-728-1338\nMobile: 678-294-3572\nrichard.laudano@broadcom.com\nwww.broadcom.com\n\n<<>>\n\nA BR\nLithium-lon Shipping Review\nBroadcom Limited Proprietary and Confidential. © 2016 Broadcom Limited. All rights reserved.\nRichard Laudano\n24 May 2016\n\n<<>>\n\n• Broadcom has continued working with IATA and suppliers to moni\n• Recently Broadcom focused its efforts to understand the interface\n• Since the battery cell in the pack has no external interface Broado\nhas changed from a lithium battery shipment (UN3480) to a lithiur\nshipment with or in equipment (UN3481), Packing Instruction 966\n• In order to more accurately describe the function the assembly, fo\nit is more appropriate to call it a cache memory back-up unit (CBL\n• The volumetric energy density of the CBU is relatively low betwee\nand impact to shipping methods.\n/ Broadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved.\nbattery backup unit (BBU)\nBroadcom Position\ncell in our application.\nWh/l.\n\n<<>>\n\nBroadcom's Cache Backup Unit (CBU) is designed to provide backı\nIf a power failure is detected, the cache memory power source is sv\nprimary to backup system power using controls resident on the RAI\nDuring power failure, the battery cell in the CBU supplies power to t\nregulation circuit contain in or attached to the module. The CBU's re\ncircuit creates all necessary voltage rails in order to provide the req\nmaintain data in the cache long enough until system power is restor\nthe RAID controller memory in the event of power loss.\nBroadcom CBU Function Details\nBroadcom Limited Proprietary and Confidential. @2016 Broadcom Limited. All rights reserved.\nboard and CBU.\n\n<<>>\n\nJustification for Changing to Packed With or In Equip\nFor the purposes of this packing instruction, IATA defines \"equipme\ndevice or apparatus for which the lithium cells or batteries will provi\nFrom the SP188(i) document: As used in this special provision \"eqi\nmeans apparatus for which the lithium cells or batteries will provide\nThe Li-lon cell in the equipment only provides power to the apparat\nwhich contains the charger chip) and the cell's interface (input or ol\nnot exit the PCBA. It looks like this does meet the current definition\nFor Broadcom's application the lithium cell only provides electrical p\napparatus (PCBA which contains the charger chip) that is either inte\nthe pack or connected via a short wire harness and has no direct ex\nAll rights reserved.\nBroadcom Limited Proprietary and Confidential. © 2016 Broadcom Limited.\npower for its operation.\npower for its operation.\n(UN3481)\ninterface.\n\n<<>>\n\nCache\nBacku\nUnit\n1.5V or 1.8V\nDRAM\nRAID Controller Car\nBACKUP\nCELL\nCACHE\n- MEMORY\n1.5V or 1.8V\nDS273:\nSWITCH MODE\nICCCV:\nPOWER\nMANAGEMENT\nSWITCHING\nREGULATOR\nPOWER\nVReg\n12V from PCle Bus\nBattery\nCell\nBroadcom CBU Block Diagram\nBroadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved.\nGreen - Power during\nBlue - Power during\nnormal operation\nback up operation\n\n<<>>\n\nBOTTOM SIDE\n1L1.2024.5\nBroadcom single cell CBU with integrated charger card\nBroadcom single cell CBU connected to charger card\nBroadcom Single Cell CBU Types\nPery is Initi\nmanufacturi\nTOP SIDE\nBroadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved.\nModel BAT151P-A\n\n<<>>\n\nFrom what you say, it sounds like the battery is an integral part of :\ncontained in equipment. If it is separate from the equipment, it she\nFrom: YMQ Dangerous Goods [mailto: dangood@iata.org]\n33, Route de l'Aeroport, 1215 Geneva 15 Airport, Switzerland\nFrom: Richard Laudano [mailto:richard.laudano@broadcom.com\nThanks for your feedback. Given the information I provided will thi\napplication where the battery cell has no interface outside of the p\nguidance and hoped your group could look at my unusual applicatic\nbut need to know if it will provide more information than the PI 96:\nSent: Tuesday, May 10, 2016 7:45 AM|\nTo: Richard Laudano; YMQ Dangerous Goods\nSubject: RE: Packed With or In Equipment?\nTo: YMQ Dangerous Goods \nManager, Dangerous Goods Standards\nInternational Air Transport Association\nSubject: Re: Packed With or In Equipment?\nwww.iata.org/dangerousgoods\nI hope this helps.\nPaul Horner\nTel: +41 22 770 2045\nFax: +41 22 770 2686\nEmail: hornerp@iata.org\nSent: 10 May, 2016 11:21 AM\nRichard,\nRegards\nPaul\nThanks\nRichard\nSent: Mon 5/16/2016 5:18\nIATA Agreement of Broadcom Position\n+ 0\nFrom the description of what you have this appears to be lithium ion batteries contained in equipment.\nAs such it is UN 3481, and must meet the applicable parts of Section Il of packing instruction 967.\nBroadcom Limited Proprietary and Confidential. ©2016 Broadcom Limited. All rights reserved.\n33, Route de l'Aéroport, 1215 Geneva 15 Airport, Switzerland\nLithium Battery Workshop\nBRUSSELS, BELGIUM 11-13 OCTOBER 2016\nRE: Packed With or In Equipment?\nYMQ Dangerous Goods\nRichard Laudano\ndangood@iata.org\nAsst. Director Cargo Safety & Standards\nInternational Air Transport Association\nPlease consider the environment before printing this email\nDavid BRENNAN\nTel: +41 22 770 2947\nMob: +41 79 505 9495\nFax: +41-22-770-2686\nemail: brennand@iata.org\nwww.iata.org/dangerousgoods\nFrom:\nSubject:\nSigned By:\nRichard.\nRegards:\n\n<<>>\n\nBroadcom Limited Proprietary and Confidential. ® 2016 Broadcom Limited. All rights reserved.\nThank You\n\n<<>>\n\nLithium Ion Batteries -\nShipping By Air\nexperience\nwhat's inside™\nOwner: Liliana Alonso\nDate: WW17 16\nDeg execution & operations\nintel)\nDatacenter Engineering Group\n\n<<>>\n\nThe International Air Transport Association (IATA) has recently made (relative\nin the regulation for transportation of Lithium-lon (Li-lon) batteries that may im\nAs of April 1st, 2016, the new IATA regulations for air transportation pertaining\n• Standalone batteries not permitted to be shipped in cargo area of passeng\n• Standalone batteries are permitted to be shipped in cargo area of air freigt\n• Batteries when contained/installed in equipment are not subject to these re\n• Batteries packed with the equipment they power are not subject to these re\n• The definition of what 'equipment' means is not 100% clear\n• The definition of what 'equipment' means is not 100% clear\ndeliver shipping products to our customers\nProblem Statement\nbe discharged to <=30%\nare summarized as follows:\nDeg execution & operations\nDatacenter Engineering Group\n\n<<>>\n\nPCSD RAID Batte\nAXXRSBBU3\nAXXRSBBUSS\nAXXRSBBU4\nAXXRSBBU6\nAXXRSBBU7\nAXXRSBBU7D10\nAXXRSBBU7S\nAXXRSBBU8\nAXXRSBBU9\nProducts Impacted:\nImpact to Commercial Business as of April 1, 2016\n• Current Intel inventory of batteries is at 45%-50% of charge. This charge ‹\n• Our battery units are physically installed to a PCB with the charging and n\n• Batteries in warehouse, disti's, etc. are on ship hold and cannot be shippe\nwhen they are built by a third party and then provided to Intel\nall cases, and are shipped to/from Intel with these connected\ncustomers\nDeg execution & operations\nDatacenter Engineering Group\n\n<<>>\n\nAfter analysis by Tiger Team and approval from Hazardous Material Intel Leader Matt Riffey and Regulat\nPasternak, current battery inventory in Intel warehouses at 45%-50% of charge should be enabled to be s\nbatteries contained in/with equipment.\" Team believes this adheres to the both the spirit and letter of the I\nstill regulated and restricted, but this designation can be shipped on passenger aircraft, the SOC is not a f\n• Enables urgent shipments for NCR that are still held in Intel warehouses to ship directly and immediate\n• Avoids scrambling to rework (no defined solution yet), and other transportation modes do not meet nee\nRisk to position: Interpretation of 'equipment' is ambiguous. When these BBU's are installed and activate\npower loss occurs, the batteries power/use the PCB and cable, but also supply power to the RAID card m\n(which is not included in the shipping equipment). The memory is on the RAID card, not on the local PCB.\nambiguous equipment definition, there is potential for whether Intel is adhering to the letter of the restrictic\nAction Requested: Inform Intel Legal of the situation and the recommendation above, and and get approv:\nFollow Up Action Required: RAID team will implement <30% SKU's over coming 2 months, and update all\nvalues, in case IATA decides to further restrict ALL batteries to this level. Broadcom has now committed t\nenable shipping of all current inventory to customers currently backlogged for units.\nand they have already started needed actions for implementation as planned.\nmove forward with shipping Li-lon BBU's as 'shipping with equipment.'\n• Immediately resolves the impact on LDT for end customer\nPosition Recommendation:\n• Avoids rework for current inventory\nsprit based on tiger team assessments).\nDeg execution & operations\nDatacenter Engineering Group\nBenefits to position:\n\n<<>>\n\nDeg execution & operations\nBackUp\nDatacenter Engineering Group\n\n<<>>\n\nRedesig\nBatte\nWith\nmill\nCells greater than\nBatteries greater\n20 Wh; and\nthan 100 Wh\nLimit per package:\nUN3481\nPI 966\nSection 1\nPax A/C = 5 kg\nIMP: RLI\nCAO = 35 kg\nNo\nCells 520 Wh; and\nBatteries ≤100 Wh\nLimit per package:\n(not moro than 1\n≤ 2.7 Wh = 2.5kg: or\ncells > 2.7 Wh ≤ 20 Wh\nUN3480\nPI: 965\nSection II\nIMP: ELI\npackage)\n= 8 cells; or\nbatteries > 2.7 Wh\n≤ 100 Wh = 2 batteries\nForbidden on Pax\n09/03/2016\nPart III Subsection\nAll cells and batteries must be tested in accordance with\n38.3 (DGR 3.9.2.6)\nPassed\nUN?\nYes\nLithium Ion Batteries\n(limited to a maximum\nof 30% SoC)\nColls ≤ 20 Wh; and\nBatteries 5100 Wh\nNOTE: Use \"IB\" 11\npackage exceeds\nSection Il Limits and\nmore than 1 package\nLimit per package:\nPax A/C = Forbidden\nUN3480\nPI 965\nSection IB\nIMP: RLI\nCAO = 10 kg\nthe UN Manual of Tests and Criteria\nall.\nCells greater than 20\nBatteries greater\nLimit per package:\nPax A/C = Forbidden\nPage 5\nWh: and\nthan 100 Wh\nUN3480\nSection IA\nIMP: RLI\nCAO = 35 kg\nPI 965\nColls equal to or\nless than 20 Wh;\nBatteries equal to\nor less than 100 Wh\nLimit per package:\nand\nUN3481\nPI 967\nSection II\nPax A/C = 5 kg\nIMP: ELI\nCAO = 5 kg\nLithium ton\nBatteries\nContained in\nEquipment\n• exceptions exist to the labelling requirements -\nIn.\nAPCS/Cargo\nClassification Flowchart - Lithium Ion Batteries\nDeg execution & operations\nCells greater than\nBatteries greater\n20 Wh: and\nthan 100 Wh\nLimit per package:\nsee PI 967 Section I|\nDatacenter Engineering Group\nUN3481\nPI 967\nSection 1\nIMP: RLI\nPax A/C = 5 kg |\nCAO = 35 kg","truncated":false,"body_characters":13468}