{"operation":"document","citation":"19-0085","title":"EnerSys — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-12-11","effective_on":null,"summary":"19-0085 response to EnerSys concerning 173.159, 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0085.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0085.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0085","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73016/190085_1.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDEC 1 1 2019\nSteve Spease\nPackaging Compliance Engineer\nEnerSys\n2366 Bernville Rd.\nReading, PA 19605\nReference No. 19-0085\nDear Mr. Spease:\nThis letter is in response to your June 21, 2019, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries. You\ndescribe a lithium ion battery that weighs approximately 50 kg, with a completely enclosed\ncasing with 1.5 mm thick steel walls. Five sides of the casing are welded together, and the sixth\nside is mechanically fastened. You state that the battery terminals will have insulators installed to\nprotect from short circuit during transportation. You also note that the batteries will be oriented\nso that the terminals do not support the weight of other superimposed elements when packaged,\nand that spacers and strapping will be used to secure the batteries to a pallet/box to prevent\nshifting during transportation.\nWe have paraphrased and answered your questions as follows:\nQ 1. You ask for confirmation that the battery packaging described above, and illustrated in\nthe photograph you provided, would meet the requirement in § 173 .185(b )( 5) to have a\n\"strong, impact-resistant outer casing.\"\nA 1. The answer is yes. Based on the pictures and information you provided, the battery\nassembly appears to be fully enclosed in its metal casing. This appears to rrieet the\nrequirements of a strong, impact-resistant outer casing as specified in § 173. l 85(b )( 5).\nQ2. You ask for confirmation that the packaging would not need UN specification packaging\nand that securing batteries to a pallet, or in a crate/box, would meet§ 173.185(b)(5) for\ntransportation by highway or vessel.\nA2. You are correct. When all other requirements of§ 173.185(b) are met in addition to using\na strong and impact resistant outer casing, UN specification packaging is not required.\nQ3. You ask for confirmation that the answer provided in a letter of interpretation (LOI)\nReference No. 05-0017 applies to your scenario, and that a highway or vessel shipment of\nthe lithium batteries you described would not constitute a bulk packaging even if the total\nweight of the pallet exceeds 400 kg.\n\n<<<PAGE 2>>>\n\nA3. The answer regarding palletized batteries in LOI Reference No. 05-0017 is specific to the\npackaging provisions for wet batteries in § 173 .15 9. However, lithium batteries secured\nto a pallet in accordance with § 173. l 85(b )( 5) would also be considered a single non-bulk\npackage. The palletized batteries should be marked and labeled as a non-bulk package\neven if the completed package weighs more than 400 kg (882 pounds).\nI hope this information is helpful. Please contact us if we can be of further assistance.\neren\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nINFOCNTR (PHMSA)\nFriday, June 21, 2019 2:55 PM\nHazmat Interps\nFW: LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING\nHi Alice and lkeya,\nPlease see the information below for a letter of interpretation request.\nThanks,\nLynsie, HMIC\nFrom: Spease, Steven [mailto:Steven.Spease@enersys.com]\nSent: Friday, June 21, 2019 2:14 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: RE : LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING\nLynsie\nThank you for the quick response .\nOur mailing address is:\nEnersys\n2366 Bernville Rd\nReading, PA\n19605\nThank you,\nSteve Spease\nEnersys\nPackaging Compliance Engineer\n610-208-1743\nFrom: INFOCNTR (PHMSA) [mailto:INFOCNTR.INFOCNTR@dot.gov]\nSent: Friday, June 21; 2019 2:12 PM\nTo: Spease, Steven\nSubject: RE: LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING\nDear Steve,\nWe have received your request for a written letter of interpretation regarding the hazardous materials regulations (49\nCFR Parts 171-180). The hazardous materials regulations are available at the following URL:\nhttp://phmsa.dot.gov/regulations\nHowever, before we can submit your request for processing, please respond to this email with:\n• Physical Mailing Address\n1\n\n<<<PAGE 4>>>\n\nSincerely,\nLynsie, Hazardous Materials Specialist\nAn e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance\nwith 49 CFR 105.20. http://phmsa.dot.gov/hazmat/regs/interps\nFrom: Spease, Steven [mailto:Steven.Spease@enersys.com ]\nSent: Friday, June 21, 2019 10:02 AM\nTo: PHMSA HM lnfoCenter <PH MSAHM lnfoCenter@dot.gov>\nSubject: LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING\nDear Sir or Madam,\nI am requesting a letter of interpretation on packaging of a lithium ion battery.\nWe have a lithium ion battery design where the battery has a mass of approximately 50kg, a casing that is approximately\n450mm x 400mm x 110mm with 1.5mm thick steel walls. Five sides of the casing are welded together with the sixth side\nmechanically fastened.\nThe battery terminals will have insulators installed to protect from short circuit during transportation. The batteries will\nbe oriented so that the terminals do not support the weight of other superimposed elements when packaged.\nSpacers and strapping will be used to secure the batteries to a pallet/box to prevent movement during transportation\nand to the protect guide pin and electronic module which are located on the outside of the casing.\nCan you confirm that the battery would meet 49CFR173.185(b)(5) as having a \"strong, impact-resistant outer casing\"?\nCan you confirm that the packaging would not need to use UN specification packaging and that securing batteries to a\npallet, or in a crate/box would meet 49CFR173.18S(b)(5) for transportation by ground or vessel?\nCan you confirm that for ground and vessel shipments of these 50kg batteries they would not constitute a bulk shipment\nwhen the total weight of the pallet/box would weigh in excess of 400kg (ie more than eight, 50kg batteries per\npallet/box) when packaged in accordance with 49CFR173.185(b)(5) (reference PMHSA Interpretation 05-0017)?\n2\n\n<<<PAGE 5>>>\n\nThank you,\nSteve Spease\nEnersys\nPackaging Compliance Engineer\n610-208-1743\n3","truncated":false,"body_characters":6256}