EnerSys — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 DEC 1 1 2019 Steve Spease Packaging Compliance Engineer EnerSys 2366 Bernville Rd. Reading, PA 19605 Reference No. 19-0085 Dear Mr. Spease: This letter is in response to your June 21, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries. You describe a lithium ion battery that weighs approximately 50 kg, with a completely enclosed casing with 1.5 mm thick steel walls. Five sides of the casing are welded together, and the sixth side is mechanically fastened. You state that the battery terminals will have insulators installed to protect from short circuit during transportation. You also note that the batteries will be oriented so that the terminals do not support the weight of other superimposed elements when packaged, and that spacers and strapping will be used to secure the batteries to a pallet/box to prevent shifting during transportation. We have paraphrased and answered your questions as follows: Q 1. You ask for confirmation that the battery packaging described above, and illustrated in the photograph you provided, would meet the requirement in § 173 .185(b )( 5) to have a "strong, impact-resistant outer casing." A 1. The answer is yes. Based on the pictures and information you provided, the battery assembly appears to be fully enclosed in its metal casing. This appears to rrieet the requirements of a strong, impact-resistant outer casing as specified in § 173. l 85(b )( 5). Q2. You ask for confirmation that the packaging would not need UN specification packaging and that securing batteries to a pallet, or in a crate/box, would meet§ 173.185(b)(5) for transportation by highway or vessel. A2. You are correct. When all other requirements of§ 173.185(b) are met in addition to using a strong and impact resistant outer casing, UN specification packaging is not required. Q3. You ask for confirmation that the answer provided in a letter of interpretation (LOI) Reference No. 05-0017 applies to your scenario, and that a highway or vessel shipment of the lithium batteries you described would not constitute a bulk packaging even if the total weight of the pallet exceeds 400 kg.#

Page 2A3. The answer regarding palletized batteries in LOI Reference No. 05-0017 is specific to the packaging provisions for wet batteries in § 173 .15 9. However, lithium batteries secured to a pallet in accordance with § 173. l 85(b )( 5) would also be considered a single non-bulk package. The palletized batteries should be marked and labeled as a non-bulk package even if the completed package weighs more than 400 kg (882 pounds). I hope this information is helpful. Please contact us if we can be of further assistance. eren Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Dodd, Alice (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Friday, June 21, 2019 2:55 PM Hazmat Interps FW: LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING Hi Alice and lkeya, Please see the information below for a letter of interpretation request. Thanks, Lynsie, HMIC From: Spease, Steven [mailto:Steven.Spease@enersys.com] Sent: Friday, June 21, 2019 2:14 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: RE : LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING Lynsie Thank you for the quick response . Our mailing address is: Enersys 2366 Bernville Rd Reading, PA 19605 Thank you, Steve Spease Enersys Packaging Compliance Engineer 610-208-1743 From: INFOCNTR (PHMSA) [mailto:INFOCNTR.INFOCNTR@dot.gov] Sent: Friday, June 21; 2019 2:12 PM To: Spease, Steven Subject: RE: LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING Dear Steve, We have received your request for a written letter of interpretation regarding the hazardous materials regulations (49 CFR Parts 171-180). The hazardous materials regulations are available at the following URL: http://phmsa.dot.gov/regulations However, before we can submit your request for processing, please respond to this email with: • Physical Mailing Address 1#

Page 4Sincerely, Lynsie, Hazardous Materials Specialist An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance with 49 CFR 105.20. http://phmsa.dot.gov/hazmat/regs/interps From: Spease, Steven [mailto:Steven.Spease@enersys.com ] Sent: Friday, June 21, 2019 10:02 AM To: PHMSA HM lnfoCenter <PH MSAHM lnfoCenter@dot.gov> Subject: LETTER OF INTERPRETATION REQUEST-LITHIUM ION BATTERY PACKAGING Dear Sir or Madam, I am requesting a letter of interpretation on packaging of a lithium ion battery. We have a lithium ion battery design where the battery has a mass of approximately 50kg, a casing that is approximately 450mm x 400mm x 110mm with 1.5mm thick steel walls. Five sides of the casing are welded together with the sixth side mechanically fastened. The battery terminals will have insulators installed to protect from short circuit during transportation. The batteries will be oriented so that the terminals do not support the weight of other superimposed elements when packaged. Spacers and strapping will be used to secure the batteries to a pallet/box to prevent movement during transportation and to the protect guide pin and electronic module which are located on the outside of the casing. Can you confirm that the battery would meet 49CFR173.185(b)(5) as having a "strong, impact-resistant outer casing"? Can you confirm that the packaging would not need to use UN specification packaging and that securing batteries to a pallet, or in a crate/box would meet 49CFR173.18S(b)(5) for transportation by ground or vessel? Can you confirm that for ground and vessel shipments of these 50kg batteries they would not constitute a bulk shipment when the total weight of the pallet/box would weigh in excess of 400kg (ie more than eight, 50kg batteries per pallet/box) when packaged in accordance with 49CFR173.185(b)(5) (reference PMHSA Interpretation 05-0017)? 2#

Page 5Thank you, Steve Spease Enersys Packaging Compliance Engineer 610-208-1743 3#