{"operation":"document","citation":"17-0053","title":"Hazardous Materials Safety Interpretation 17-0053","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-11-14","effective_on":null,"summary":"17-0053 concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0053.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0053.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0053","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56231/170053_0.pdf","body":"<<<PAGE 1>>>\n\nHonda Power Equipment Manufacturing Inc.\nP.O. Box 37\n3721 NC Highway 119\nSwepsonville, NC 27359\nReference No. 17-0053\nDear Mr. Gregory:\nThis letter is in response to your May 18, 2017 and May 22, 2017, emails requesting clarification\nof the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging\nand shipping requirements for \"UN3481, Lithium ion batteries contained in equipment.\" You\nseek guidance on the acceptable level of protection provided by the following packaging\nscenario:\n• The lithium ion battery is installed inside a pedestrian-controlled lawn mower;\n• The battery's terminals are connected to the lawn mower;\n• The battery is secured by a latch;\n• The equipment is protected from accidental activation by a switch near the battery that\nrequires a plastic clip to continue normal functionality of the lawn mower; and\n• The \"bail\" and a separate button on the \"blade control bail\" provide additional protection\nfrom accidental activation.\nWe have paraphrased and answered your questions as follows:\nQ1.\nYou ask if it is acceptable to ship a lithium ion battery contained in equipment (i.e., a\nlawn mower).\nAl.\nThe answer is yes, provided the lithium ion battery complies with the applicable\nrequirements of § 173.185 and the equipment is packaged in a manner to prevent short\ncircuits, movement (i.e., shifting) within the outer package, and accidental activation of\nthe equipment while in transportation.\nQ2.\nYou ask what level of protection is acceptable to prevent short circuits and accidental\nactivation of the lithium ion battery when contained in a lawn mower.\nA2. As provided by § 173.185(b), the shipper must ensure that the lithium ion battery and the\nequipment as presented for transport are packaged in a manner to prevent short circuits,\n\n<<<PAGE 2>>>\n\n\"Tr\nQ3.\nYou ask if the lithium ion battery can be connected to a key-activated lawn mower.\nA3.\nThe answer is yes, provided the equipment is secured against shifting within the outer\npackaging and packed to prevent accidental operation during transport (see\n§ 173.185(b) (4)(ii)).\nQ4.\nYou ask if enclosing a lithium ion battery in a plastic outer cover provides adequate\nprotection from short circuit.\nA4.\nAs provided by § 173.185(b), the shipper must ensure that the lithium ion battery and the\nequipment as presented for transport are packaged in manner to prevent short circuits,\nshitting within the outer package, and accidental activation of the equipment. There is\nnot sufficient information included in your email to provide a definitive answer.\nHowever, it is the opinion of this Office that if your plastic outer cover is non-metallic,\ncompletely encloses the cells or batteries, and separates the cells or batteries from contact\nwith the equipment, other devices, or conductive material, then placement in a plastic\nouter packaging would be adequate protection against short circuit.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nPlease submit this as a letter of interpretation. I spoke with Mr. Gregory.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Steven R Gregory [mailto:steven_gregory@hpe.honda.com]\nSent: Monday, May 22, 2017 2:03 PM\nTo: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>\nSubject: RE: UN3481 and Lithium-ion batteries\nHello,\nI am writing to request a letter of interpretation regarding the matter referenced in the attached message and discussed\nover the phone with a member of the hazmat information center on 5/22/2017.\nBased on the discussion, it is my understanding that for the purpose of shipping a 432 Wh Lithium Ion battery with\nrecessed connection terminals, the battery can be shipped following the instructions of UN3481, PI 967 Section I for\nLithium Ion Batteries Contained in Equipment. The battery will be certified to have met the requirements of the sixth\nedition of UN 38.3 for transportation of lithium-ion batteries.\nIn this case the equipment referenced would be a pedestrian-controlled lawnmower that is powered by the\naforementioned removable Lithium-lon rechargeable battery.\nThe battery will be secured inside the equipment by a latch, and the terminals of the battery would be connected to the\nlawnmower.\nThe equipment is protected from accidental activation by a switch located near the battery inside its enclosure that\nwould require the insertion of a plastic clip that engages the normally open switch.\nFurther protection from accidental activation would be provided by requiring two additional actions to start the device\nonce the clip is inserted (the blade control bail has a separate button that must be pressed before pulling the bail back -\nsimply pulling back on the bail without first pressing the button will not activate the unit).\nBased on my research into this matter, there is no additional requirement of physically blocking the connection to the\nbattery (for instance covering the terminals with electrical tape to prevent engaging with the equipment, which would\nprevent the battery from latching in place) due to the protections provided by the equipment and secure enclosure of\nthe battery in this case.\nIf I can clarify any of the above, please do not hesitate to contact me.\n\n<<<PAGE 4>>>\n\nSkype For Business: https://meet.lync.com/globalhonda-hpe/steven_gregory/1N6JRW6W\nFrom: Steven R Gregory\nSent: Thursday, May 18, 2017 1:32 PM\nTo: 'phmsa.hm-infocenter@dot.gov' <phmsa.hm-infocenter@dot.gov>\nSubject: UN3481 and Lithium-ion batteries\nHello,\nI have some questions regarding shipping a lawn mower using UN3481 PI 967 Section I.\nI have reviewed the applicable regulation and still have some questions about what is allowed.\nWould it be acceptable to ship with the battery installed in equipment?\nThe regulation states the battery should be protected from short circuit and accidental activation of the equipment -\nwhat level of protection is deemed acceptable?\nCan the battery be connected to the mower if a key needs to be inserted in a slot next to the battery in order to activate\nthe equipment?\nIf the battery is fully enclosed in a plastic outer cover is that considered adequate protection from short circuit?\nPlease advise.\nThank you,\nSteven Gregory\nTest Engineer | Quality Regulatory Compliance Dept\nHonda Power Equipment Mfg. Inc.\n(336) 395-6178\n(336) 395-4217\nsteven gregory@hpe.honda.com\nSkype For Business: https://meet.lync.com/globalhonda-hpe/steven_gregory/1N6JRW6W\nConfidentiality Notice: This transmission (including any attachments) may contain confidential information\nbelonging to the sender and is intended only for the use of the party or entity to which it is addressed. If you are\nnot the intended recipient, you are hereby notified that any disclosure, copying, distribution, retention or the\ntaking of action in reliance on the contents of this transmission is strictly prohibited. If you have received this\ntransmission in error, please immediately notify the sender and erase all information and attachments.\n2","truncated":false,"body_characters":7103}