# Bluesmart, Inc — Hazardous Materials Safety Interpretation

**Citation:** 16-0124  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-03-06

16-0124 response to Bluesmart, Inc concerning 175.10.

## Document text

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
MAR 0 6 2018
Mr. Brian Chen
VP of Operations
Bluesmart, Inc.
729 Minna Street
San Francisco, CA 94103
Reference No. 16-0124
Dear Mr. Chen:
This letter is in response to your July 15, 2016, email requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR parts 171-180) applicable to a suitcase containing a
lithium ion battery when carried aboard aircraft.
You state that your company manufactures and sells a suitcase that uses a non-removable
lithium ion battery with a 39.52 Wh rating. You further explain that the battery powers the
main functions of your suitcase, which include: a Bluetooth enabled lock; a built-in digital
scale; a GPS location tracker; and USB ports to allow users to charge their portable electronic
devices. Specifically, you seek confirmation of your understanding that this suitcase is
authorized to be carried by passengers or crew if conforming to the portable electronic device
provisions for passengers and crew aboard aircraft in § 17 5 .10( a)( 18) and electronic
transmission requirements in 14 CFR part 91, § 91.21 .
Your understanding of the requirement in§ 175.10(a)(18) is correct. According to the
information in your email and the supplemental attachments provided, the suitcase meets the
criteria for a portable electronic device prescribed in§ 175.1O(a)(l8). When carried by
passengers or crew members for personal use, such suitcases that conform to the applicable
provisions for portable electronic devices may be carried in either checked or carry-on
baggage.
You should be aware that an FAA Information for Operators (InFO) 17008: The
Transportation Portable Electronic Devices (PED) in Checked Baggage has been published on
this issue and can be found on FAA's website at www.faa.gov. The InFO advises that devices
containing lithium batteries should be transported in carry-on baggage and not placed in
checked baggage. When that is not possible, the devices should be completely powered down
to the OFF position, protected from accidental activation, and packed so they are protected
from damage.

<<<PAGE 2>>>

It is also important to note that the International Civil Aviation Organization (ICAO) during
the twenty-sixth meeting of the Dangerous Goods Panel in Montreal, Canada on October 16
thru 27, 2017 adopted a new requirement that will require luggage equipped with a lithium
battery to be carried as carry-on baggage, unless the battery is removed from the luggage.
This new requirement will become effective in the January 2019 Edition of the ICAO
Technical Instructions. This implementation will be applicable for all international
transportation and on any air carriers that implement the ICAO or IA TA requirements as
policy. You should always verify the air carrier policies prior to transportation.
In addition to the HMR requirements, all applicable FAA requirements must be complied
with, including those in 14 CFR, § 91.21 that address operation of portable electronic
devices aboard aircraft. Information and guidance to assist with compliance of this
requirement can be found in Advisory Circular (AC) 91.21 -lC, titled "Use of Portable
Electronic Devices Aboard Aircraft." For additional information regarding the FAA
requirements or if you seek an interpretation on whether your particular device meets
electronic transmission requirements contained in 14 CFR § 91 .21 you may contact the FAA
at the following address:
Federal Aviation Administration
Office of the Chief Counsel
Regulations Division
800 Independence Avenue SW
Washington, DC 20591
In addition to the transportation safety requirements pertaining to this device, there may be
additional security requirements issued by the Transportation Security Administration.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
-
~.- /' I
I I ,
1'-1· / '--!--'---· ---·· . I
./ ,:;"' I.
Duane A. Pfund I
International Program Coordinator
Standards and Rulemaking Division
~----· / -

<<<PAGE 3>>>

- ~ · ?<.!-~
'd I 70. JO. 78
t3~ 1 6 -- C)/ Q? <(
Dodd, Alice (PHMSA)
From:
Sent:
To:
Subject:
Attachments: Rivera, Jordan CTR (PHMSA)
Monday, July 18, 2016 10:08 AM
Hazmat Interps
FW: Bluesmart Request for Interpretation
Request for Letter of Interpretation.pdf; UN38.3 Report.pdf; Exhibit C.pdf; Exhibit B.PDF;
Exhibit D.pdf; Exhibit A.PNG
Hi Shante/Alice,
Please submit this as a letter of interpretation. Mr. Chen's contact information is:
Bluesmart
33 Irving Pl
New York, NY 10003
206-605-6328
Please let me know if you have any questions.
Thanks,
Jordan
From: Brian Chen [mailto:brian@bluesmart.com]
Sent: Friday, July 15, 2016 12:25 PM
To: PHMSA HM InfoCenter
Subject: Bluesmart Request for Interpretation
To Whom It May Concern:
Please find attached a Request for Interpretation in regard to the carry-on suitcase designed and sold by Bluesmart Inc.
Should you require original copies of any documentation or any additional information, I would be happy to send. Please
let me know if you have any questions.
I look forward to hearing back. If you could provide a sense for when we can expect to hear back, that would be greatly
appreciated.
Best,
Brian
Brian Chen
Co-Founder & VP Operations
1

<<<PAGE 4>>>

o 0o bluesmart
0
July 14, 2016
U.S. Department of Transportation
PHMSA Office of Hazardous Materials Standards
Attn: PHH-10
East Building
1200 New Jersey Avenue, SE
Washington, DC 20590-0001
Re: Request for Letter of Interpretation
To Whom It May Concern:
Our company, Bluesmart Inc., sells and manufactures a carry-on suitcase that utilizes a
lithium ion battery. The primary use of the battery in the suitcase is to power the main
functions of our suitcase, which include a Bluetooth-enabled lock, a built-in digital scale,
and 3G + GPS location tracking. As a secondary function of the battery, USB ports are
provided to allow users to charge their portable electronic devices. We would like to
request a letter of interpretation in regard to the inclusion of the Lithium-Ion battery.
It is our understanding that our product complies with 49 CFR §175.10.18 due to the
fact that: 1) our battery is "installed"; 2) is "of a type proven to meet the requirements of
each test in the UN Manual of Tests and Criteria, Part Ill, Sub-section 38.3"; and 3) has
a Watt-hour rating of 39.52 Wh. For reference, please find enclosed the UN38.3 test
results and the Material Safety Data Sheet we use when shipping our product.
To provide additional context around the design of our product, the battery in our carry-
on suitcase is not removable, and the housing has been designed for maximum safety.
In addition to the images included in the UN38.3 test results, see Exhibit A, which
shows the location of the battery housing within the suitcase shell. See Exhibit B for a
more detailed layout of how the battery housing design. See Exhibit C for additional
information on the flame retardant materials used in the housing.
Finally, it is our understanding that our product complies with FAA Advisory Circular
(AC) 91.21-1C dated 5/7/2015 (specifically Section 8) due to having three different
means of turning off electronic transmissions. First, users can turn the suitcase off
manually via the on/off switch. Second, users can turn the suitcase off via the mobile
application that connects to the suitcase. Finally, we have developed algorithms and
Bluesmart Inc.
729 Minna St
San Francisco, CA 94103
bluesmart.com

<<<PAGE 5>>>

o0o bluesmart
0
conducted tests to ensure the automatic shutdown of electronic transmissions upon
flight takeoff. See Exhibit D for a brief memo that explains our methodology and results.
We request a letter of interpretation so that we may confirm the compliance of our
product with current regulations. Should you require further information to make your
interpretation, please do not hesitate to contact us.
Thank you in advance for your response.
Best Regards,
Brian Chen
VP of Operations
Bluesmart Inc.
729 Minna St
San Francisco, CA 94103
bluesmart.com

<<<PAGE 6>>>

"'''''',.
MA
]lac-MRÁ
CNAS
t#S Rep No. SET2015-12702
2012002402H
CNAS L1659
TEST REPORT
Client Name
Zhongshan Tianmao Battery Co.,LTD.
Name of product
Li-ion Battery
Manufacturer
Zhongshan Tianmao Battery Co.,LTD.
TMB/BP702
Trade mark & model
Test sort
Safety Entrust Test
/
Address: Building 28, 29, Shigu east, Xili Factory Distric, Xiliac, Nanshan District, ShenZhen, Guangdong, China
what/Internet: http://www.ccic-set.com
LIF/TEL: 86-755-26628136
#71#/E-Mail: sophie.wang@ccic-set.com
14M1/FAX: 86-755-26701436
CCIC-SET/TRF (00)
page
of
16 H

<<<PAGE 7>>>

tR# mE Rep No. SET2015-12702
CCIC Southern Electronic Product Testing (Shenzhen) CO., Ltd.
TEST REPORT
Name of sample
Li-ion Battery
"Trade mark
TMB
Manufacturer
Zhongshan Tianmao Battery Co.,LTD.
Model/Type
BP702
Client
Zhongshan Tianmao Battery Co.,LTD.
Sampling method
Sent by client
Application data
2015/07/31
Completing Date
2015/08/27
811Ш, 2511tỲt
Quantity of sumples
8 Batteries, 25 Cells
Environment
condition
15~35°C 45~75%RH
Nominal voltage
3.8V
Limited Charge
Voltage
4.3V
39.52Wh/10
Rate Energy/Capacity
400mAh
Standard charge
current
1040mA
Max. Charge Current
3120mA
End Charge
Current
208mA
Cut-off Voltage
2.75V
Max. Discharge Current
5200mA
Compumerells
4PCS
KiKi. IT F(Test item):
Testl: A/24ID Altitude simulation
Test2: i/Eit. Thermal Test
Test3: #eż)) Vibration
Test4: 7titi Shock
Tests: 31-*i* External short circuit
Testo: 1d//FImpact/Crush
Test7: W3# Overcharge
Test8: 55(# Forced discharge
1 01# (Reference documents):
ЙL$П.
«Recommendations on the Transport of Dangerous Goods,Manual of Test and Critera) section
38.3:Lithium metal and lithium ion batteries (ST/SG/AC.10/11/Rev.5/Amend. 1&Amend2).
* KAES (Summary):
Each Cell/battery type is subjectd to tests 1 to 8,Tests 1 to 5 are conducted in sequence on the same
Cells/batteries, Tests 6 and 8 are conducted using not otherwise tested Cells/batteries, Test 7 using undamaged
batteries previously used in Tests 1 to 5.
CCIC-SET/TRF (00)
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of

<<<PAGE 8>>>

* # # Rep No. SET2015-12702
Di ##A* Mass loss%=(M,-M,)/M, ×100
"Fithh".
Where M, is the mass before the test and M2 is the mass after the test. When mass loss does not exceed the
values in Table 38.3.2.2, it shall be considered as "no mass loss".
Mass M of cell or battery
Mass loss limit
M<lg
0.5%
IgsM≤75g
0.2%
M> 75g
0.1%
In test 1 to 4 batteries meet this requirement if there is no leakage,no venting, no disassembly, no rupture
and no fire and if the open circuit voltage of each test battery after testing is not less than 90% of its voltage
immediately prior to this procedure.
*YE (Remark) :
Batteries of B01#-B04# are fully charege at first cycle.
Component cells of C9#-C13# at 50% of the design rated capacity at first cycle.
Batteries of BO5#-B08# are fully charege after 50 cycles.
** 5 014#-
Component cells of C14#-C23# at first cycle in fully discharged states.
Component cells of C24#-C33# are fully Discharge after 50 cycles.
* KaKlite (Test conclusion):
Goods,Manual of Test and Critera.
The test samples comply with section 38.3 of Recommendations on the Transph of Dangerous?
Tested by
Periowed b
Approved by
2015 ÷ 08H27 H
2015 7: 08 / 27 |
2015 ÷: 08 / 27 П
CCIC-SET/TRF (00)
#
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3
5# 16 B
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<<<PAGE 9>>>

~&15-t!iil~ Rep No. SET2015-12702
W1~ 1 i\'/fit;flf Test Procedure
r~i~I.m
Pretreatment
fiJ; lC,
Marking
ft Rn t\iU 1% Samples
of: BO 1 #-BOS#
;t:t i:i~ r,1;,1 -'% Samples
of: C09#-Cl3#
+t Rn WU -5 Samples
of: B01 #-B08#
t"f Rn rj] -'% Samples
of: C l4#-C33#
f@i & t.Utf
Altitude simulation
l
yifilj}f li\%7.
Thermal test
l
i*M
Vibration
'
t!ilm·rtff IF.
Impact/Cmsh
lift:
Overcharge
~_ti\ f#lj /jj: fTI
Forced dischage
5Hflg '1'r
E.xter:nal short
ClfClllt
.____, l
'---~~~~~~~~---,;--~~~~~~~~~
iG!l.t
Finished test
CCIC-SET/TRF (00) ~ 4 ".m' ;J:t I 6 ".m'
page of

<<<PAGE 10>>>

*B*** Rep No. SET2015-12702
WiSH Test results:
Test T.I iA/. Altitude siuiation
it 52 Test method:
Batteries are stored at a pressure of 11.6 kPa or less for at least six hours at ambient temperature (20t5°C).
* * Requirement:
pen circuit voltage of each test battery after testing is not less than 90% of its voltage immediately prior to thi
Batteries meet this requirement if there is no leakage, no venting, no disassembly, no rupture and no fire and if the
iN id*tRAn F# Test Date showed in table below:
DIRt
Pre-test
After test
State of sample
No.
Mass
Voltage after
Mass
(g)
Voltage
(V)
Mass
Voltage
loss
test/Voltage
(V)
(%)
pre-test(%)
Status
BO1#
178.230
4.34
(g)
178.195
4.33
0.02
99.77
PASS
At first cycle in
B02#
178.564
4.33
178.560
4.32
0.00
99.77
PASS
fully charged
B03#
178.443
4.34
178.430
4.34
0.01
100.00
PASS
states
BO4#
178,352
4.33
178.347
4.32
0.00
99.77
PASS
BO5#
178.640
4.34
178.581
4.32
0.03
99.54
PASS
F, 5823014
After 50 cycles
BOG#
178.551
4.34
178.548
4.32
0.00
99.54
PASS
ending in fully
B07#
178.446
4.34
178.435
4.32
0.01
99.54
PASS
charged states
B08#
178.232
4.33
178.220
4.32
0.01
99.77
PASS
#YE Notes:
Ambient temperature:24.7°C.
After the test, the batteries are no leakage, no venting, no disassembly, no rupture and no fire.
CCIC-SET/TRF (00)
page
# ≤ BI# 16 B

<<<PAGE 11>>>

=g Rep No. SET2015-12702
Test T.2: / if Thermal test
WiSE Test method:
Batteries are to be stored for at least six hours at a test temperature equal to 75+2°C, followed by storage for at least
six hours at a test temperature equal to -40+2°C. The maximum time interval between test temperature extremes is
30 minutes. This procedure is to be repeated 10 times, after which all test batteries are to be stored for 24 hours at
ambient temperature (20+5 C).
#* Requirement:
open circuit voltage of each test battery after testing is not less than 90% of its voltage immediately prior to this
Batteries meet this requirement if there is no leakage, no venting, no disassembly, no rupture and no fire and if the
procedure.
WitH! F# Test Date showed in table below:
SHIA
Pre-test
After test
#ALt
State of sample
No.
Mass
Voltage after
Mass
(g)
Voltage
(V)
Mass
Voltage
loss
test/Voltage
(V)
(%)
pre-test(%)
Status
(g)
BOI#
178.195
4.33
178.172
4.25
0.01
98.15
PASS
At first cycle in
BO2#
178.56
4.32
178.512
4.25
0.03
98.38
PASS
fully charged
B03#
178.430
4.34
178.393
4.28
0.02
98.62
PASS
states
BO4#
178.347
4.32
178.336
4.24
0.01
98.15
PASS
BOS#
178.581
4.32
178.543
4.23
0.02
97.92
PASS
After 50 cycles
BO6#
178.548
4.32
178.521
4.24
0.02
98.15
PASS
ending in fully
B07#
178.435
4.32
178.410
4.23
0.01
97.92
PASS
charged states
B08#| 178.220
4.32 178.192
4.24
0.02
98.15
PASS
it Notes:
Ambient temperature:24.7°C.
After the test, the batteries are no leakage, no venting, no disassembly, no rupture and no fire.
CCIC-SET/TRF (00)
page
# E# 16 51

<<<PAGE 12>>>

#R#S Rep No. SET2015-12702
Test T.3: #z)) Vibration
# iF Z Test method:
16·*···*·
# 200t*24.
logarithmic sweep between 7 Hz and 200 Hz and back to 7 Hz traversed in 15 minutes. This cycle shall be repeated
Batteries are firmly secured to the platform of the vibration machine ,The vibration is a sinusoidal waveform with a
directions of vibration must be perpendicular to the terminal face.
12 times for a total of 3 hours for each of three mutually perpendicular mounting positions of the cell. One of the
reached. The amplitude is then maintained at 0.8 mm (1.6 mm total excursion) and the frequency increased until a
The logarithmic frequency sweep is as follows: from 7 Hz a peak acceleration of 1 gn is maintained until 18 Hz is
peak acceleration of 8 g, occurs (approximately 50 Hz). A peak acceleration of 8 g, is then maintained until the
#* Requirement:
frequency is increased to 200 Hz.
fire and if the open circuit voltage of each test battery after testing is not less than 90% of its voltage immediately
Batteries meet this requirement if there is no mass loss, no leakage, no venting, no disassembly, no rupture and no
prior to this procedure.
Wit thun F# Test Date showed in table below:
Pre-test
After test
State of sample
No.
Mass
Voltage after
Mass
(g)
Voltage
Mass
(g)
Voltage
loss
test/Voltage
(V)
(%)
pre-test (%)
Status
(V)
BO1#
178.172
4.25
178.172
4.25
0.00
100.0
PASS
At first cycle in
B02#
178.512
4.25
178.512
4.25
0.00
100.0
PASS
fully charged
B03#
178.393
4.28
178.393
4.28
0.00
100.0
PASS
states
B04#
178.336
4.24
178.336
4.24
0.00
100.0
PASS
#1-1301x
BOS#
178.543
4.23
178.543
4.23
0.00
100.0
PASS
5, 50230r
After 50 cycles
/ BOG#
178.521
4.24
178.521
4.24
0.00
100.0
PASS
ending in fully
B07#
178.410
4.23
178.410
4.23
0.00
100.0
PASS
charged states
BO8#
178.192
4.24
178.192
4.24
0.00
100.0
PASS
7VE Notes:
Ambient temperature:24.8 °C
After the test, the batteries are no leakage, no venting, no disassembly, no rupture and no fire
CCIC-SET/TRF (00)
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7
of

<<<PAGE 13>>>

#R# Rep No. SET2015-12702
Test T.4: if Shock
Wit 75it Test method:
each test battery. Each battery is subjected to a half-sine shock of peak acceleration of 150 gn and pulse duration of 6
Batteries are secured to the testing machine by means of a rigid mount which will support all mounting surfaces of
negative direction of three mutually perpendicular mounting positions of the battery for a total of 18 shocks.
milliseconds. Each battery is subjected to three shocks in the positive direction followed by three shocks in the
# * Requirement:
open circuit voltage of each test battery after testing is not less than 90% of its voltage immediately prior to this
Batteries meet this requirement if there is no leakage, no venting, no disassembly, no rupture and no fire and if the
procedure.
it#* Hi! F # Test Date showed in table below:
Pre-test
After test
State of sample
No.
Mass
Voltage after
Mass
(g)
Voltage
(V)
Mass
Voltage
loss
test/Voltage
(V)
(%)
pre-test (%)
Status
(g).
BO1#
178.172
4.25
178.172
4.25
0.00
100.0
PASS
At first cycle in
B02#
178.512
4.25
178.512
4.25
0.00
100.0
PASS
fully charged
B03#
178.393
4.28
178.393
4.28
0.00
100.0
PASS
states
BO4#
178.336
4.24
178.336
4.24
0.00
100.0
PASS
BOS#
178.543
4.23
178.543
4.23
0.00
100.0
PASS
After 50 cycles
/ BO6#
178.521
4.24
178.521
4.24
0.00
100.0
PASS
ending in fully
B07#
178.410
4.23
178.410
4.23
0.00
100.0
PASS
charged states
B08#
178.192
4.24
178.192
4.24
0.00
100.0
PASS
#id: Notes:
Ambient temperature:23.8°C.
After the test, the batteries are no leakage, no venting, no disassembly, no rupture and no fire.
CCIC-SET/TRF (00)
page

<<<PAGE 14>>>

* #9 Rep No. SET2015-12702
Test T.5:4t-M5xti* External short circuit
it Test method:
battery are subjected to a short circuit condition with a total external resistance of less than 0.1 ohm at 55 ‡ 2 °C.
Batteries be tested are temperature stabilized so that its external case temperature reaches 55 - 2 °C and then the
to 55 + 2 °C. The batters are observed for a further six hours for the test to
This short circuit condition is continued for at least one hour after the battery external case temperature has returned
** Requirement:
rupture and no fire within six hours after test.
Batteries meet this requirement if their external temperature does not exceed 170 °C and there is no disassembly, no
WitE 41 T'# Test Date showed in table below:
HAVE
State of sample
No.
Highest temperature (°C)
Status
B01#
55.4
PASS
BO2#
55.5
PASS
At first cycle in fully
charged states
B03#
55.5
PASS
B04#
55.1
PASS
BO5#
55.5
PASS
After 50 cycles
BO6#
55.6
PASS
ending in fully
B07#
55.2
PASS
charged states
BO8#
55.7
PASS
#it: Notes:
Ambient temperature: 24.4°C.
After the test,the batteries are no disassembly, no rupture and no fire within six hours.
CCIC-SET/TRF (00)
page

<<<PAGE 15>>>

#$ Rep No. SET2015-12702
Test T.6:# /17/ Impact/Crush
Miti Impact(applicable to cylindrical cells not less than 18mm in diameter)
WidE Test method;
cm long, or the longest dimension of the cell, whichever is greater, Type 316 stainless steel bar is to be placed
The sample cell or component cell is to be placed on a flat smooth surface. A 15.8 mm +0.1mm diameter, at least 6
intersection of the bar and sample in a controlled manner using a near frictionless, vertical sliding track or channel
across the centre of the sample. A 9.1 kg ‡ 0.1 kg mass is to be dropped from a height of 61 + 2.5 cm at the
with minimal drag on the falling mass. The vertical track or channel used to guide the falling mass shall be oriented
The test sample is to be impacted with its longitudinal axis parallel to the flat surface and perpendicular to the
90 degrees from the horizontal supporting surface.
longitudinal axis of the 15.8 mm + 0.1mm diameter curved surface lying across the centre of the test sample. Each
sample is to be subjected to only a single impact.
#//Crush (applicable to prismatic, pouch, coin/button cells and cylindrical cells not more than 18 mm in
diameter)
it/2 Test method;
approximately 1.5 cm/s at the first point of contact, The crushing is to be continued until the first of the three
Cells or componert cell is to be crushed between two flat surfaces. The crushing is to be gradual with a speed of
options below is reached.
The applied force reaches 13 kN ÷ 0.78 kN;
The voltage of the cell drops by at least 100 mV; or
The cell is deformed by 50% or more of its original thickness.
* * Requirement;
#WAiX—™*.
disassembly, no rupture and no fire during the test and within six hours after test.
Cells or componert cell meet this requirement if their external temperature does not exceed 170 °C and there is no
CCIC-SET/TRF (00)
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<<<PAGE 16>>>

t&Effili~ Rep No. SET2015-12702
iiJ!1J~i\ ~ :JJ.!f:!L11T: ~ Test Date showed in table below;
W!H. i\JlJJ I§ r t - ~· !#iJ 1E
State of sample Test item No. Status
C09# PASS
- · 1-Jri n!l E\:l, JWJ 1JJ
50% i&H ~I ll li:'. ~:j:
CIO# PASS
t'TJ.E
~ *
1D ' Cll# PASS
At first cycle at 50% Crnsh
of the design rated Cl2# PASS
capacity C l 3# PASS
n~~~
1irtt Notes:
~~~ ft #~~ rr ~ ~ M ~ ~~~~€6~~~~~~. ~ ~~.~~*· ~m~ ~ ~ . 5~ .
Cells or componert cell are no disassembly and no fire during the test and within six hours after test.
Ambient temperature:24.5 'C .
CCIC-SET/TRF (00) 1« 11
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<<<PAGE 17>>>

#R #4#5 Rep No. SET2015-12702
Test T.7:113t'L Overcharge
WidJ52 Test method:
$17.
when the manufacturer's recommended charge voltage is not more than 18V, the minimum voltage of the test
shall be the lesser of two times the maximum charge voltage of the battery or 22V.
b ФёФ
when the manufacturer's recommended charge voltage is more than 18V, the minimum voltage of the test shall
be 1.2 times the maximum charge voltage.
Tests are to be conducted at ambient temperature. The duration of the test is 24 hours.
I * Requirement:
test.
Batteries meet this requirement if there is no disassembly and no fire during the test and within seven days after the
it Hath F Test Date showed in table below:
Totenti
2x5200mA=10400mA
Overcharge current:
Overcharge voltage :
2x4.35V=8.70V
Total time of charging:
24hours
State of sample
No.
Status
B01#
PASS
BO2#
PASS
At first cycle in fully
charged states
B03#
PASS
BO4#
PASS
BOS#
PASS
BOG#
PASS
After 50 cycles ending in
fully charged states
BO7#
PASS
B08#
PASS
TYt: Notes:
temperature:24.5°C.
The Batteries are no disassembly and no fire during the test and within seven days after the test, Ambient
CCIC-SET/TRF (00)
page
12 F# 16 A
of

<<<PAGE 18>>>

#R#*m 9 Rep No. SET2015-12702
Test T.8:J4 #Jirt Forced discharge
Wit Test method:
supply at an initial current equal to the maximum discharge current specified by the manufacturer.
Each component cell is forced discharged at ambient temperature by connecting it in series with a 12V D.C. power
# * Requirement:
Rechargeable cells meet this requirement if there is no disassembly and no fire during the test and within seven days
after the test.
WiFT # Test Date showed in table below:
State of sample
No.
Status
C14#
PASS
CIS#
PASS
C16#
PASS
C17#
PASS
C18#
PASS
At first cycle in fully
discharged states
C19#
PASS
C20#
PASS
C21#
PASS
C22#
PASS
C23#
PASS
C24#
PASS
C25#
PASS
C26#
PASS
C27#
PASS
C28#
PASS
After 50 cycles ending it
ully discharged states
C29#
PASS
C30#
PASS
C31#
PASS
C32#
PASS
C33#
PASS
7YL Notes:
temperature:24.6°C.
After the test, the Component cells are no disassembly and no fire during the test and within seven days, Ambient
CCIC-SET/TRF (00)
page
of

<<<PAGE 19>>>

~IH1i·tlffl~ Rep No. SET2015-12702
OOJt Photo 2
CCIC-SET/TRF (00)
~ 14
page
16 YI

<<<PAGE 20>>>

t!Xi5-tllij-5- Rep No. SET2015-12702
fi: n7i Im )]" Photo document
lfilft Photo 3
lfilft Photo 4
CCIC-SET/TRF (00)
~ 15
page
16 JD:
JD:~
of

<<<PAGE 21>>>

#&#*#₴ Rep No. SET2015-12702
##
STATEMENT
*, üE#5: L1659o
This test laboratory is accredited by CNAS, Accreditation Certificate No.1659.
The test report is invalid without stamp of laboratory.
The test report is invalid without signature of person(s) testing and authorizing.
The test report is invalid if erased and corrected.
Test results of the report is valid to the test samples if sampling by client.
6. CNAS *#*"*"#.
"I" item cannot be Accredited by CNAS.
The test report shall not be reproduced except in full, without written approval of the laboratory.
If there is any objection to report,the client should inform issuing laboratory within 15 days from the date of
receving test report.
##=^**0*·XFX*28.29k$
Address: Building 28, 29, Shigu cast, Xili Factory District, Xili Road, Nanshan District, ShenZhen, Guangdong, China
BEX 95084/P.C.: 518055
LIF/TEL: 86-755-26628136
pxt:/Internet: http://www.ccic-set.com
#-1##/E-Mail: sophie.wang@ccic-set.com
1t#/FAX: 86-755-26701436
CCIC-SET/TRF (00)
#
page
16 5#165
of

<<<PAGE 22>>>

AF-312C
ABS : Flame retardant Grade
~ Application
(TBBA flame retardants)TV, VTR, printer. facsmilie, computer, monitor. Electric parts requiring
flame retardant property.
• Feature
AF-312C is specifically engineered to meet the need for high performance products in the flame
retardant resin applications. AF-3 I 2C provides an optimum balance of physical properties.high
heat resistance, outstanding UV stability and good finished part aesthetics.
• Prope rti es
Physical Method Condition Unit Value
ASTM D1238 200'C i5kg g/1 Om in 6.5
Melt Index ASTM D I 238 220"C/10kg g/10min 55
ASTM D1238 230'( /3 .8kg g/ 1 Om in 16
Spec ific Gravity ASTM D792 23 c - 1.18
Mold Shrinkage ASTM D955 - % 0.4-0. 7
Mechanical Method Condition Unit Value
Tensile Strengn1 at
Yield
ASTM D638 50mm/min kg/cm· 440
Tensile Modulus ASTM D638 50mm/min kg/cm· 22.000
Elongation at Yield ASTM D638 50mm/min 9'0 5
Elongation at Break ASTM D638 50mm/min % 20
Flexural Strength ASTM D790 15mm/min kg/en( 710
Flexural Modulus ASTM D790 15mm/min kg/cm' 25.000
ASH.11 D256 1/4".23( kg-cm/cm 25
ASTM D256 l/4",-30'(' kg cm/cm 8
IZOD Impact strength
ASTM D256 I /8 . ,23'C kg cm/cm 3 1
ASTM D256 1/8" ,-30 c kg-cm/cm 8
Thermal Method Condition Unit Value
ASTM D648 1/4',18.5kg/cn( ·c 74
(unannealed)
1/4" ,4. 6kg/cm'
ASTM 0648
·c 88
Heat Deflection Temp (annealed)
ASTM D648
1I4 • ,4. 6kg/cm· ·c 84
(unannealed)
l/4". 18.5kg/cm'
http://www.chemwide.co.kr/product3/0matter/printgradedtl .jsp ?gradeSeq=909&locale=en&uni . . . 07129105

<<<PAGE 23>>>

ASTM 0648 (annealed) oc 83
Flammability Method Condition Unit Value
Flammability UL94 I I 1 O" class V-0
~ l G Ctwrn Fax:82- 2- 3773 -7802 I Email: lgwebmaster@lgchem.com
http://www.chemwide.eo.kr/product3/0matter/printgradedtl.jsp?gradeSeq=909&locale=en&uni ... 07129105

<<<PAGE 24>>>

REVISIONS
REV Description : Drawn by: Date:
A Bottom Piece Assembl
--
Batterv Housin
Size of Batte
Batterv To
c I I c
A
0
Lf)
0
~
Note:
1) The 1.Smm thickness ABS plastic housing is
flame retardent.
2) Battery housing material is A BS A F312C
3) Shock is reduced by adding the EV A
foams in the housing.
0
0
A
EVA foam(shock reduction
~"
SECTION A-A
~ EVA Foam (shock reduction)
Batterv Bottom Housin
@ ~ Q:!J@~[M@[? (S
The drawing and specifications are the properity of Bluesmart and shall not be
reproduced, copied or used in any manner without the proir written consent of
Blues mart.
Tolerence unless
otherwise stated :
x.x ±0.2
x.xx ±0.1 0
x.xxx ±0.050
Angels ±0.5°
B luesmart part name :
Cabin_Bottom_piece
Bluesmart part No :
Material:
ABS AF312C
UNIT:
MM
Item : Descriptions : Specification : Material: Qty : Remark:
Scale:
l :2
Date :
Approved by :
Project name :
MD
Cabin
2016-06-08
Designer:
EZ
SHT No: REV :
A3

<<<PAGE 25>>>

AUTOMATIC CONTROL FOR RADIO FREQUENCY
COMPLIANCE
Bluesmart
Abstract
In this brief document, we present the sensors and algorithms used by the Carry-on developed by Bluesmart
to assure that the onboard wireless module complies with current federal regulations. A real flight case study is
presented.
I. INTRODUCTION
The carry-on developed by Bluesmart (C0-01), is different from other wireless communication devices
i.e. cellular phones, in the main fact that the cellular network is used at intervals, rather than, being
constantly connected and sending-receiving information. To assure that the C0-01 is safe and does not
interfere with any airplane communication and/or navigation instruments we develop a set of algorithms
and rules that prevent the C0-01 to broadcast data or connect to the network while the aircraft is in flight.
For the purpose of this document we will use the following definition of in-flight: "Any time from the
moment all the external doors of an aircraft are closed following embarkation until the moment when any
such door is opened for disembarkation[ ... ]". 1 Next we will present the sensors used and its characteristics.
Then we described the process "Crosscheck" used to inhibit wireless communication while flying. Finally
an example of a real flight is shown with the automatic detections performed with the computer onboard
the luggage.
II. SENSORS
A set of sensors are used to identify the different parts of the flight. A 3-axis accelerometer, a barometer,
a thermometer and a clock are embedded in the C0-01. Next we present the Barometer.
A. Barometer
The barometer, an IC used to measure pressure, with this data altitude can be computed. The barometer
is heavily affected by noise, bias and drift. Sample data for a static case is shown in fig. 2. To reduce
the effect of the noise an Infinite Impulse Response filter is used to obtain a better measurement. A
comparison between this two values are shown in fig. 2. The barometer will be used in two scenarios.
The first scenario is to assure that whenever the aircraft closes the doors the cellular functions (if being
used) are immediately terminated, and disabled. In the second scenario, will determine if the movement
in the aircraft is ascending or descending.
B. Accelerometer
The second sensor available is a three axis accelerometer. With this sensor the acceleration in three
axis of the C0-0 I can be meassured. This sensor as well is very noise and a filter is used to obtain a
pristine value. A sample filtered data is shown in fig. 3. We calibrate the accelerometer before we use it.
In the next section we present and discuss the "crosscheck".

<<<PAGE 26>>>

27590
1 11
27585 II
27580
G 27575 l
0
<l'.
I
27570
I
27565 -
27560 I "
0 100 200 300 400 500 600 700 800
Time [s]
Fig. I. Barometer sample raw data
27590 1
I
27585
27580
~
u 27575
0
<l'.
27570
27565 -
27560 I I I
0 100 200 300 400 500 600 700 800
Time [s]
Fig. 2. Barometer fitlered data
III. CROSSCHECK
The main objective of the crosscheck algorithm is to disable wireless communications when the aircraft
is on the air. The accelerometer is used to detect large accelerations changes. This large accelerations
indicate that the aircraft is changing its movements. This movements will indicate, increase in speed,
decrease in speed, increase in altitude, decrease in altitude or attitude changes. The barometer is used to
characterize the type of movement detected with the accelerometer. If the pressure increase, will indicate
altitude lose. With pressure decrease will indicate and increment in altitude. Spikes in pressure indicates
attitude changes. No variations on pressure indicates linear speed changes. We use mathematical methods 2

<<<PAGE 27>>>

30
,.. '
-20 -
I
6
Time [Hr]
8
Fig. 3. Accelerometer measurements
10 12
to detect the different e.dges on the curve. With this curves and comparing to the patterns of the aircraft
we identify if the aircraft is on the air or not. The aircraft is identified as being in flights after the
accelerometer detect the increase in the acceleration during take off followed by the pressure drop due to
the climbing. Once the acceleration is detected the communications are inhibited to prevent the wireless
communications to go off during takeoff. The The main drawback of this method is that will fail to
prevent wireless emissions from the moment the door close to the moment where the take off run stars.
To prevent wireless communication in this periods of time we use a background check.
The Background check is used to sample the barometer and intervals to verify that the door has not
been close. To identify the door close an abrupt change in the pressure output will occur. When this
jump occurs the communications are inhibited as to prevent wireless communications. Once the flag of
door-close is set the communications are inhibited and the crosscheck process continues as stated above.
A plot showing an example of real door close is shown in fig. 4.
The algorithms discussed above are implemented in the embedded computer inside the C0-01. These
algorithms are constantly running in the background to assure that the crosscheck can function regardless
of the user intervention and travel schedule. The algorithms are implemented to run on real time, hence the
data is being discarded as soon as is processed to protect the users privacy. For the purpose of debug some
C0-01 where modified as to record the entire data and different flight moments identifications. A sample
trial from a real flight is shown in fig. 5. The plot is for a 10:00 Hr flight. There are two zones clearly
marked. In blue, are the areas that represent the aircraft on the ground with the door open. In red, from
door close till door open. These sections where identified with the crosscheck algorithm automatically.
IV. CONCLUSIONS
First we presented the sensors incorporated in the Carry-on developed by Bluesmart. Then, the different
algorithms used to assure that no wireless communications are performed during flight were introduced.
Finally, sample data from a real flight where shown. From the data shown is clear that the algorithm
presented in this brief document clearly can capture the flight of the aircraft. With this algorithms the
wireless communications are effectively inhibited during the flight of the aircraft. This assure that the
Carry-on is safe to be carry on any aircraft.

<<<PAGE 28>>>

27565
27560
u
0
<l'.
27555
27550
'J ~ " 1
I I Ill l'JlL I JmllJll' lllJ . . lll 1···1
u U L,J !_ I , , UUIL Ii i LL
27545 ~-~-----~-----~-~-----~~~
800 820 840 860 880 900
920 940 960
Time [s]
Fig. 4. Door close sample data
40 , 000 ~--------------------------~
30,000
(j)
-0
2 20,000
:;::;
<( 10,000
o t=:l_- ---'------'--------------------'-'
0 2 4 6
8 10
Time [Hr]
c
0
~
(j) 0 -~"·-....==~~--~~--~-~-------'--~--~~~~~~
Qi
(.)
(.)
<(
-50 ~----~---~~----------------~
0 2 4 6
8
10
Time [Hr]
Fig. 5. Door close sample data
REFERENCES
[1] F. A. Regulation, "Part 01 ," DEFINITIONS AND ABBREVIATIONS, 1990.
[2] W. Swokowski, Calculus, ser. Available Titles Cengagenow. Brooks/Cole, 1991.

<<<PAGE 29>>>

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/57436/160124.pdf>
- Source ID: `phmsa`
- SHA-256: `73de2c914334df2ac06328f217e548f2b74d9e63f4f84477ced8737e0d820672`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-24T05:09:41.962Z
- Document slug: `phmsa-interpretation-16-0124`

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