# ILS Manager - Aircraft — Hazardous Materials Safety Interpretation

**Citation:** 08-0052  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2008-03-26

08-0052 response to ILS Manager - Aircraft concerning 173.185.

## Document text

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
MAR 2 6 2008
1200 New Jersey Avenue, SE
Washington, D.C. 20590
Mr. Greg Hardwick
ILS Manager - Aircraft
13350 US Highway 19 North
Clearwater, FL 33764
Ref. No.: 08-0052
Dear Mr. Hardwick:
This is in response to your letter dated February 26,2008, concerning requirements in the
Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80) applicable to the transportation
of navigation equipment containing two lithium-thionyl chloride (Li-SOCL2) batteries. In your
letter you reference existing letters of interpretation issued by this office (Ref. No.: 07-0055 and
07-0202) and ask for a final interpretation that clarifies whether you should continue shipping
your navigation equipment as Class 9 material or begin shipping it as nonregulated. According
to your letter, each Li-SOCL2 battery contained in the navigation equipment has a lithium
content of approximately 1.7 grams.
The letters of interpretation you reference are both accurate. We a final rule entitled
"Hazardous Materials; Transportation of Lithium Batteries" (HM-224C & HM-224E; 72 FR
44929) on August 9,2007. The rule becomes effective on October 1,2008, but voluntary
compliance was authorized as of October 1,2007. Therefore, you may use the "old" or "new"
requirements until October 1,2008. This overlap accounts for the apparent differences between
the two letters. Letter no. 07-0055 discusses the requirements that are currently effective (old)
and the requirements that will become effective on October 1,2008 (new), while letter no. 07-
0202 focuses solely on the requirements that are currently effective (old). Copies of the
rulemaking and letters are enclosed for your convenience.
Since you are already transporting the navigational equipment as a Class 9 material, I suggest
you align your shipping practices with the August 9,2007 rulemaking in preparation for the
October 1,2008 effective date. Please refer to letter of interpretation no. 07-0055 for additional
information on shipping your navigational equipment.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely, ,-
'Chief, Standards Development
Office of Hazardous Materials Standards

<<<PAGE 2>>>

---- Original Message-----
From: PHMSA-Feedback [mailto:PHMSA-Feedback]
Sent: Tuesday, February 26, 2008 2:46 PM
To: HMIS <PHMSA>; PHMSA Web Initiative
Subject: Feedback: Hazardous Materials Regulations Question
Please reference Hazardous Material Interpretations ID# 07-0202 and 07-0055.
As the Honeywell authority for transportation of Lithium batteries here at
our Clearwater, EL facility, I would appreciate a final interpretation from
your office regarding the transportation of Lithium batteries contained in
Equipment. Honeywell provides navigation equipment to the military all over
the world and delivers each item with two (2) medium ?C? size Primary
Lithium Thionyl-Chloride batteries, each with 1.79 Li contained in the
equipment.
Further battery facts and transportation details are as follows:
? The batteries are shipped as contained in the equipment and contain
the necessary number of batteries only to power the equipment
? The battery and the navigation equipment are designed with the
appropriate safety features ? diode or?ing to prevent reverse current flow,
safety vent, short circuit protection, etc.
? Each battery when fully charged contains < 2.0 grams Li
? The net weight of the batteries < 5kg
? The battery vendor reports this battery to meet the UN Manual of Tests
and Criteria
As the competent DOT authority for transportation of Lithium batteries
Honeywell would appreciate your ruling on the proper shipping method of the
Lithium Battery Contained in equipment and if in fact they these batteries
can be shipped UN-Regulated or if we should continue shipping each item as a
Class 9 material.
Thank You,
Greg Hardwick
Honeywell DSES - Clearwater
ILS Manager - Aircraft
ph. (727) 539-4890, fax (727) 539-4893
email: greg.hardwick@honeywell.com
-----------
Greg Hardwick
Affiliation: Industry (Honeywell International)
13350 U.S. Highway 19 north
Clearwater, Flo 33764
Phone: 727-539-4890
Fax: 727-539-4893
Email: greg.hardwick@honeywell.com

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080052.pdf>
- Source ID: `phmsa`
- SHA-256: `c500737c48b240216d73a8ed7feb8dc30749687423506096f321d359830ef734`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T13:52:03.974Z
- Document slug: `phmsa-interpretation-08-0052`

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