{"operation":"document","citation":"24-0094","title":"ABS All Battery Service GmbH — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-04-03","effective_on":null,"summary":"24-0094 response to ABS All Battery Service GmbH concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0094.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0094.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0094","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-05/240094.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nApril 3, 2025\nEva Glimsche\nABS All Battery Service GmbH\nSperberstraße 50e\n81827 Munich, Germany\nReference No. 24-0094\nDear Ms. Glimsche:\nThis letter is in response to your October 15, 2024, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium battery\ntest reports. Specifically, may a manufacturer redact some information from a lithium battery\ntest report and does the lithium battery test report example included with your email provide the\nnecessary information to meet the requirements in 49 CFR § 173.185(a)(3)?\nThe HMR do not prohibit redaction of some information from lithium battery test reports;\nhowever, the full lithium battery test report must be made available by the manufacturer to an\nauthorized representative of the Federal, state, or local government upon request—see 49 CFR\n§ 173.185(a)(2)(ii). In addition, as required by 49 CFR § 173.185(a)(3), each manufacturer and\nsubsequent distributor must make available a lithium battery test summary that includes the\nfollowing elements:\n• Name and address of the cell, battery, or product manufacturer including address,\ntelephone, email, and website;\n• Name and address of the test facility including address, telephone, email, and website;\n• A unique test report number;\n• Date of the test report;\n• Cell or battery description including if the battery is lithium ion or lithium metal, the\nbattery’s mass, watt-hour rating or lithium content, physical description of the\ncell/battery, and model number;\n• List of tests conducted;\n• Reference to assembled battery testing requirements, when applicable;\n• Edition of United Nations Manual of Tests and Criteria used; and\n• Name and title of responsible person.\n\n<<>>\n\nUpon review, it appears that the redacted lithium battery test provided with your email is\nincomplete. Required information such as the test report number, name of testing laboratory,\nand name and title of responsible person are redacted.\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<<>>\n\nPollack\n24-0094\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Request for a written letter of clarification\nDate: Tuesday, October 15, 2024 4:54:38 PM\nAttachments: PHMSA-UN383-test-summary-with-two-mistakes-anonymized-2024-10-15.png\nHello Alice,\nPlease see the below interpretation request. Let us know if you need anything.\nSincerely,\nJanaye\nFrom: Eva Glimsche \nSent: Tuesday, October 15, 2024 4:17 AM\nTo: INFOCNTR (PHMSA) \nSubject: Request for a written letter of clarification\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.\nDear PHMSA team,\nwe were asked by one of our customers to check a UN 38.3 test summary for plausibility and\ncompleteness.\nThe battery manufacturer is seated in the USA.\nWhen doing so we had two findings:\n1. The version given in the UN 38.3 test summary did not match the version of the Manual of Tests\nand Criteria that was valid at the date of testing.\nWe did request the battery manufacturer to correct the UN 38.3 test summary and we received the\nreply that the battery was tested according to 7th revised edition even if the test report was from\n2023.\n2. No test institute was entered in the UN 38.3 test summary we received.\nAsking for the test institute we received the following statement:\n\"To clarify, that information does need to be passed on to regulatory authorities requesting the\nsummary like, the FAA, IATA, etc but, it does not need to be passed on to anyone else, at our\ndiscretion. If any of those agencies need a non-redacted copy, they will ask us for one. At that\npoint, we have a \"reasonable\" amount of time to provide the document to them, per part 4, section\nH of the document you sent me. Nobody else needs a non-redacted copy for any reason.\nIf you are requesting this document from us for transportation purposes, the copy I sent you will\n\n<<>>\n\nsatisfy the transporters, as they do not need a non-redacted copy. I hope that helps.\"\nNow we would like a written letter of clarification whether the statements this battery manufacturer\nmade under list point 1 and under list point 2 reflect the PHMSAs point of view.\nFor reference I have attached the anonymized version of the UN 38.3 test summary we received as\ndocument\nPHMSA-UN383-test-summary-with-two-mistakes-anonymized-2024-10-15\nThank you very much for looking into this.\nBest regards,\nEva Glimsche\n\n<<>>\n\nEva Glimsche\nABS All Battery Service GmbH\nSperberstr. 50e – 81827 Munich - Germany\nOffice +49 - 89 - 43579624\nMobile +49 - 171 – 4958177\neva.glimsche@lithium-battery-service.com\nwww.lithium-battery-service.com\nCEO: Eva Glimsche and Juergen Werny\nRegistered office: Munich\nCommercial Register: Amtsgericht München (district court Munich) HRB 296612\n\n<<>>","truncated":false,"body_characters":5299}