SAFT America Inc — Hazardous Materials Safety Interpretation

Page 1! of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. Research and 20590 Special Programs Administration APR 2 9 1998 Mr. Chip Wildes Environmental, Safety and SAFT America Inc Recycle Manager 711 Industrial Blva. Valdosta, GA 31601 Dear Mr. Wildes: This letter is a revision of previous opinions you received classification of "líthium ion" bätteries under the Hazardous from us dated March ], 1994 and April 10, 1995, regarding the Materials Regulations (HMR; 49 CFR parts 171-180) . Based on additional information, we have determined that lithium ion cells and batteries accordance with § 173.185. section 173.185 regulates lithiu must be classified in on cells and batteries based on the amount of lithium in th anodes of the fully charged cells and batteries. If lithium ion cells and batteries meet the conditions for the exception provided in $ 173.185 (b), they are not subject to apply. the HMR. If not excepted, the other provisions of § 173.185 I hope this information is helpful. Sincerely, Materials Standards#

Page 2of Transportation U.S. Department Research and dashirator DC Special Programs Administration APR 101995 Mr. Chip Wildes Environmental, Safety and SAFT America Inc. Recycle Manager 711 Industrial Blvd. Valdosta, GA 31601 Dear Mr. Wildes: This is in response to your letter of March 21, 1995 regarding the correct classification of "lithium ion" batteries. According to the information you provided, SAFT's lithium ion battery has lithium or lithium alloys. lithium nickel oxide and carbon electrodes but contains no metallic It is the shipper's responsibility to properly classify a hazardous definitions contained in Part 173 of the Hazardous Materials Regulations material. If a material does not meet any of the hazard class (HMR; 49 CFR Parts 171-180), the material would not be subject to the above described battery is a dry battery because it does not contain any Based on the information provided, it is our determination that the hazardous material. Dry batteries are not subject to the HMR. I hope this information is helpful. Sincerely, Vietnes fillings Chief, Delmer F. Billings Office Regulations Development of Hazardous Materials Standards#

Page 34 U.S. Department of Transportation 400 Seventh Street. SW Research and Washington, D C 20590 Administration Special Programs MAR € 1095 Mr. Chip Wildes Environmental, Safety and SAFT America Inc. Recycle Manager 711 Industrial Blva. Valdosta, GA 31601 Dear Mr. Wildes: This is in response to your letter of February 6, 1995 regarding the correct classification of "lithium ion" batteries. According to the information you provided, SAFT's lithium ion battery has natural graphite. a positive electrode of lithium cobaltate and a negative electrode of lithium hexafluorophosphate, diethyl carbonate and diethyl carbonate. The electrolyte consists of ethylene carbonate, However, there is no lithium metal present at any time. Based on the information provided, it is our determination that the above Hazardous Materials Regulations (49 CFR Parts 171-180). described battery is a dry battery. Dry batteries are not subject to the I hope this information is helpful. Sincerely, Velon felling, : Delmer F. Billings Office of Hazardous Materials Standards Chief, Regulations Development •.. -#