I've had multiple designs with lithium-thionyl chloride cells get through
UL (and various other compliance) tests.
Mine were smaller though; 2/3 AA vs your D. Also, the enclosures weren't
sealed.
The impression I got from the tests was that basically they didn't care
as long as a few conditions were met:
1. There must be a reliable way of making sure the charging current is
never greater than the datasheet max value (assume 0.0uA if one isn't
specified).
2. The maximum discharge current is limited. I think that might be more
related to temperature rise rather than current per se.
3. The temperature range was limited.
4. There is no chance of mechanical penetration.
Note that those tests may be performed with a specified number of faults
(typically one) active.
Example 1. You need to meet the reverse current spec with your reverse
current protection diode shorted out.
Example 2. If you have a DC/DC converter on the board (it might be
unrelated, but still thermally coupled), give it a reasonable current
limit, which will control temperature rise when a short circuit happens.
Also, if using e.g. current limiters, using ones that already have UL
recognition may make your own approval process easier.
Your test lab may have different ideas. Talk to them.
Regards,
Allan