{"operation":"document","citation":"98-0228","title":"American Power Conversion — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-06-28","effective_on":null,"summary":"98-0228 response to American Power Conversion concerning 173.159.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0228.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0228.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0228","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980228.pdf","body":"<<<PAGE 1>>>\n\nS. Departmer\nTransportatic\n. 400 Seventh Street, S.W.\nWashington, D.C.\n20590\nJUN 28 1999\nMr. Neil Rasmussen\nRef. No. 98-0228\nVice President, Chief Technical Officer\nAmerican Power Conversion\n755 Middlesex Turnpike\nBillerica, MA 01821-3945\nDear Mr. Rasmussen:\nThis is in response to your letter dated July 31, 1998, requesting clarification on shipping batteries\nmanufactured by your company under the provisions in § 173.159(d) of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Specifically, you are requesting clarification on whether\nyour shipping scenario meets the requirements of § 173.159(d). which require batteries to be protected\nagainst short circuits and securely packaged.\nAccording to your letter, your shipping scenario is as follows:\n• A product with a sealed lead-acid battery is shipped with the battery installed in the product and\nconnected by wires to a printed wiring board assembly where the high power battery connections of\nboth polarities of the battery are directly connected to multiple adjacent exposed copper pads and\ntraces and to various electronic components. The exposed connections may be bridged by foreign\nmatter in such a way that the foreign matter or the electrical components could become energized and\ndissipate sufficient power to generate combustion. Combustion is demonstrated to trigger a sustained\nelectrical fire not limited by a protective device.\nSection 173.159(d) does not address the situation where a battery is connected to a device (product).\nThe scenario described above indicates that the batteries as packaged may allow combustion and short\ncircuits to take place. It is the opinion of this Office that the configuration of a battery connected to a\ndevice (product) as described in your letter, does not provide protection to prevent a short circuit.\nI hope this answers your inquiry.\nSincerely,\nDelo\nDelmer F. Billings\nengs\nChief, Standards Development\nOffice of Hazardous Materials Standards\n980228\n173,159\n\n<<<PAGE 2>>>\n\nPolydores\nAPC®\n$ 173.159\nAMERICAN POWER CONVERSION\n755 Middlesex Turnpike\nBillerica, MA 01821-3945\nTel: (978) 670-2440\nFax: (978) 670-2380\n× 206\nJuly 31, 1998\nMr. Delmar Billings\nOffice of Hazardous Material Standards\nChief of Standards Development\n400 7\" Street SW\nDept. of Transportation\nWashington, DC 20590\nDear Mr. Billings,\nprevious letter, I explained how we discovered an industry-wide hazard related to certain battery powered\nAs we discussed, APC is attempting to lead our industry in improving transportation safety. In my\nproducts. To help us bring together industry members and focus their attention on this issue; we are\nrequesting clarification on the interpretation of Final Rule dated Sept 30, 1993 paragraph 173.159(d)\nregarding sealed lead batteries which states:\n\"The battery must be protected against short circuits and securely packaged\"\nconsidered compliant with this regulation or any other related régulations, the characteristics being:\nWe are requesting you to advise us as to whether a product with the following characteristics would be\nthe product and connected by wires to a printed wiring board assembly where the high power\nA product with a sealed lead-acid battery, where during shipment the battery is shipped installed in\nbattery connections of both polarities of the battery are directly connected to multiple adjacent\nexposed copper pads and traces and to various electronic components, and where the exposed\nconnections may be bridged by foreign matter in such a way that the foreign matter or the\nelectrical components could become energized and dissipate sufficient power to generate\ncombustion, and further where such combustion is demonstrated to trigger a sustained electrical\nfire not limited by a protective device.\nregarding this subject:\nBased on our telephone conversation, I believe i understood you to say approximately the following\nA product with the characteristics described above does not meet the requirement since foreign\n\"short circuits\" within the meaning of the regulation and if the product behaves as described in the\nmaterials bridging the described printed wiring assembly could reasonably be characterized as\nquestion it cannot be considered to be \"protected\" against this type of event.\n113.\nAmerican Power Conversion is an Affirmative Action / Equal Opportunity employer. APC's quality system is ISO 9002 certified.\n\n<<<PAGE 3>>>\n\nIf you could provide this answer or whatever you think is the most appropriate answer in writing it would\nfacilitate the focus of our industry and be greatly appreciated. It is our intention at APC to combine our\nsafety research findings with your reply and present an advisory notice to leaders in our industry which we\nhope will lead to product design improvements that will improve transportation safety in our industry. In\naddition, it is my hope that we can develop industry standards or make recommendations back to the DOT\ncategories that use batteries.\non regulation changes or clarifications that can formalize these safety improvements across many product\nRegards,\nNeil Rasmussen\nVice President\nChief Technical Officer","truncated":false,"body_characters":5141}