{"operation":"document","citation":"19-0110","title":"Aclara — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-12-20","effective_on":null,"summary":"19-0110 response to Aclara concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0110.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0110.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0110","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73066/190110.pdf","body":"<<<PAGE 1>>>\n\n0\nU.S. Department of Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDEC 2 0 2019\nBill Laudolff\nSr. Mechanical Engineer\nAdara\n30400 Solon Road .\nSolon, OH 44136\nReference No. 19-0110\nDear Mr. Laudolff:\nThis letter is in response to your August 29, 2019, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery\ntesting. Specifically, you seek clarification of the requirements to test certain battery\nconfigurations in accordance with the United Nations (UN) Manual of Tests and Criteria and\nconfirmation that the battery configurations meet the requirements of § 173 .185 of the HMR and\nmay be offered for transport.\nIn your email, you provide the following conditions of the battery arrangements:\n• Single cell batteries are permanently installed on a circuit board and then mounted\ninto the final equipment, i.e. the battery is connected to the equipment with\nadequate protections and will not provide power to any other equipment.\n• Each single cell lithium metal battery meets all the requirements and has been\ntested in accordance with the UN Manual of Tests and Criteria.\nYou further describe five battery configurations:\n1. 2. 3. 4. 5. Multiple single cell batteries, each with less than 1 gram of lithium content,\nconnected in parallel with a total of not more than 2 grams of lithium content per\nassembly.\nMultiple single cell batteries, each with less than 1 gram of lithium content,\nconnected in series with a total of not more than 2 grams of lithium content per\nassembly.\nMultiple single cell batteries, each with more than 1 gram of lithium content,\nconnected in parallel.\nMultiple single cell batteries, each with more than 1 gram oflithium content,\nconnected in series.\nAny combination of series and parallel connections of single cell batteries.\n\n<<<PAGE 2>>>\n\nYou ask if each of the battery configurations described require additional testing in accordance\nwith the UN Manual of Tests and Criteria.\nThe answer is yes. Section 173.185(a) of the HMR states that lithium batteries are subject to the\ntests in sub-section 38.3 of the UN Manual of Tests and Criteria, regardless of whether the cells\nused to construct the battery are of a tested type. In Part III, Sub-section 38.3 of the UN Manual\nof Tests and Criteria, a battery is defined as \"two or more cells which are electrically connected\ntogether and fitted with devices necessary for use, for example, case, terminals, marking and\nprotective devices.\" Based on the information provided in your email, it is the opinion of this\nOffice that because the cells are electrically connected, whether in series or parallel, and fitted\nwith devices necessary for use, such as a circuit board, this arrangement would meet the\ndefinition of a battery. Therefore, in accordance with § 173.185(a), each battery would need to\nmeet the criteria in Part III, Sub-section 38.3 of the UN Manual of Tests and Criteria.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject: \\C\\-0110\nINFOCNTR (PHMSA)\nFriday, August 30, 2019 ll:40 AM\nHazmat Interps\nFW: Test Requirements for Single Cell Lithium Metal Battery Arrangements in\nEquipment.\nHello Alice and lkeya,\nPlease see below for letter of interpretation request.\nThe requester spoke with Josh in the HMIC, Josh provided him with letter 18-0065 and conferred with Ryan Larson to\nanswer his question. Bill still sent in for a LOI request, I found letter 17-0101 after looking through his LOI request and\ncalled him to show him the 17-0101 letter. He still insisted on requesting the LOI stating that the 17 letter addresses\nmaking a battery pack that powers something but in his case the batteries are directly installed in equipment and he\nwants to know if they are still treated as individual batteries or do they become a battery assembly even though they are\npart of the final equipment and aren't being used to power something else. He states the batteries are inseparable from\nthe equipment and the connections are made inside the equipment.\nPlease let us know if you have any further questions.\nThank you,\nKathryn, HMIC\nFrom: Laudolff, Bill [mailto:blaudolff@aclara.com]\nSent: Thursday, August 29, 2019 3:33 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: Test Requirements for Single Cell Lithium Metal Battery Arrangements in Equipment.\nTo Whom It May Concern,\nI am seeking written clarification of the requirements to test certain configurations per the Manual of Tests and Criteria\nto confirm that a battery arrangement meets the requirements of 49 CFR 173.185 and may be offered for transport.\nDo each of the following arrangements require additional tests of the arrangement per the tests specified in the Manual\nofTests and Criteria?\nThe conditions of the arrangements are as follows:\n• Single cell batteries are permanently installed on a circuit board and mounted in the final equipment, i.e. battery\nis connected to the equipment with adequate protections and will not provide power to any other equipment.\n• Each single cell lithium metal battery meets all requirements and has been tested per the Manual of Tests and\nCriteria.\nThe arrangements are:\n1. Multiple single cell batteries, each of less than lg lithium content, connected in parallel and not more than 2 g\nper assembly.\n2. Multiple single cell batteries, each of less than lg lithium content, connected in series and not more than 2 g per\nassembly.\n1\n\n<<<PAGE 4>>>\n\n3. 4. 5. Multiple single cell batteries, each of more than lg lithium content, connected in parallel.\nMultiple single cell batteries, each of more than lg lithium content, connected in series.\nAny combination of series and parallel connections of single cell batteries.\nBest Regards,\nBill Laudolff\nS1. Mechanical Engineer\nAclaro coo Save the date for AdaraConnect '20\nP 440 528 7406 [· blaudolff@aclara.com W: aclara.com A: 30400 Solon Rd, Solon, OH 44136\nThis e mail is intended for the aclcl,essee shown. Should you have received it in e110 1 , please delete this message and contact the sender. This e-mail and any attachments thereto\nmay contain information that is privileged, confidential 01 proprietary. Any review, dissPm ination or use of this transmission 01 its conten ts by persons other than the adrl,essee\n0 1 authorized employees of the intended organizations is strictly prohibited.\n2","truncated":false,"body_characters":6621}