{"operation":"document","citation":"24-0064","title":"TriEnda — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2024-09-09","effective_on":null,"summary":"24-0064 response to TriEnda concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0064.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0064.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0064","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-09/240064.pdf","body":"<<>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nSeptember 9, 2024\nJacob Hacker\nBusiness Development Manager\nTriEnda\nN7660 Industrial Road\nPortage, WI 53901\nReference No. 24-0064\nDear Mr. Hacker:\nThis letter is in response to your June 26, 2024, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the packaging requirements\nfor lithium ion batteries. Specifically, you state that a customer is requesting your company\nmanufacture a packaging for six lithium ion batteries consisting of a plastic pallet base, a plastic\nouter sleeve, and a plastic pallet lid banded together and holding two foam trays inside which\ncontain the six individual batteries. You state that each battery weighs 56.7 kg and has a strong,\naluminum outer casing. Lastly, in your email you provide drawings of the proposed\nconfiguration and a picture of a single lithium ion battery. You ask whether the foam trays\n“holding” the batteries need to meet the inner packaging requirements specified in § 173.185(b).\nThe answer is no. Section 173.185(b)(3)(i) requires lithium cells or batteries to be placed in non-\nmetallic inner packagings that completely enclose the cells or batteries and separate the cells or\nbatteries from contact with equipment, other devices, or electrically conductive materials (e.g.,\nmetal) in the packaging. The packaging configuration described in your letter would not meet\nthis requirement because the inner packaging does not completely enclose the batteries.\nHowever, in accordance with § 173.185(b)(5), lithium cells or batteries that weigh 12 kg or more\nand have a strong, impact-resistant outer casing, may be packed on pallets or other handling\ndevices instead of packages meeting the UN performance packaging requirements of\n§ 173.185(b)(3)(ii) and (b)(3)(iii), including the inner packaging requirement of\nparagraph (b)(3)(i). Provided that the battery casing is strong and impact-resistant, the lithium\nion batteries are secured to prevent inadvertent shifting, and the terminals do not support the\nweight of other superimposed elements, it is the opinion of this Office that the packing and\nhandling arrangement you describe in your email is acceptable for highway transportation in\naccordance with § 173.185(b)(5).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nEamonn Patrick\nActing Chief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\nLarson\n24-0064\nFrom: INFOCNTR (PHMSA)\nTo: Hazmat Interps\nSubject: FW: UN Battery Packaging Question / Verification\nDate: Wednesday, July 17, 2024 3:48:38 PM\nAttachments: logo.png\nfacebook-grey.png\ntwitter-grey.png\nlinkedin-grey.png\nyoutube-grey.png\ntrienda_auto_2023_banner.png\nimage001.png\nimage002.png\nimage003.png\nimage004.png\nimage005.png\nHello,\nBelow is a request for letter of interpretation.\nThe physical mailing address is:\nTriEnda\nN7660 Industrial Road\nPortage, Wisconsin\n53901\nThanks,\nJonathon\nFrom: Jacob Hacker \nSent: Wednesday, June 26, 2024 10:37 AM\nTo: INFOCNTR (PHMSA) \nCc: Andy Axelsen \nSubject: UN Battery Packaging Question / Verification\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nGood morning,\nI am with TriEnda a reusable plastic manufacturing company and we are working on a project\nfor a customer and was directed to you from our UN Testing facility to reach out for\nverification. We would like to ask a few questions around the inner packaging requirements of\nour pack and if this is compliant with your DOT regulation.\nHere is our proposed packaging for 6 batteries. Plastic pallet base, plastic outer sleeve, and a\nplastic pallet as the lid banded together. The 2 foam trays on the inside hold the batteries and\n\n<<>>\n\nkeep them separated as a load unit. My question is around the 2 foam trays holding the\nbatteries and the UN Inner Packaging requirement.\n\n<<>>\n\nSo below is the picture of the exact battery and the battery weight is 56.7 kg so we check that\nbox of being over 12 kg. They performed a 1.1 m drop test on the actual battery and thus did\nnot meet the 1.2 m drop test required for the verification of the outer casing battery drop test.\nThey did confirm that the outer casing of the battery is aluminum and all the elements of the\nbattery is enclosed. The customer questioned the highlighted statement above meets the\nimpact resistant outer casing requirement even without a 1.2m drop test.\nThey still want our packaging to be UN tested and approved. So total loaded pack weight with\nbatteries is 825 lbs so we are planning on doing the 5 side drop test for UN packaging\napproval. I know we have the Outer packaging requirement met with the pallet/sleeve/pallet\nlid, but my question is if the foam trays holding the 6 modules on the inside meet Inner\npackaging requirements or if that foam needs to completely enclose each battery and have\nthe foam fill the inside of the packaging?\n\n<<>>\n\nTransportation Mode\nRoad / Rail (ADR/RID), Sea Freight (IMDG Code)\nNominal Energy\n> 100 Wh (per battery)\nName and Description\nBatteries\n(without equipment)\n(at least one battery which is not\nBatteries packed with equipment\nE\nattached)\n5)\nSpecial Provision /\nPacking Instruction\nP903, LP903\nSP 390, P903, LP903\nMax. Quantity\nADR 1.1.3.6: max. 333 kg (per transport unit, e.g. truck incl. trailer)\nIf exceeded, further requirements for vehicle equipment and driver\nWeight Limit\nn/a\nPackaging\nbe protected to prevent short circuits\nBatteries must be placed in inner packagings that completely enclose the battery, batteries must\npackaging (Packing Group Il: e.g. UN/4G/Y30/...)\nBatteries must be secured against movement within the outer packaging. UN approved\np\nMarking\n(10 cm × 10 cm)\nHazard label No. 9A\n(10 cm x 10 cm)\nHazard label No. 9A\nUN 3480\nADR:\nADR:\nIMDG Code:\nUN 3481\nLITHIUM-ION BATTERIES UN 3480\nIMDG Code:\nLITHIUM-ION BATTERIES PACKED WITH EQUIPMEN\nLITHIUM-ION BATTERIES CONTAINED IN EQUIPMEI\nSea Freight Container-\nMarking\n(min. 25 cm x 25 cm)\nContainer Plackards\n\n<<>>\n\nThanks\nJacob Hacker\nBusiness Development Manager\nDirect 608.742.9467 or 2298 Mobile 608-566-4447\nEmail jhacker@trienda.com Website www.trienda.com","truncated":false,"body_characters":6520}