NSWC Crane Division — Hazardous Materials Safety Interpretation

Page 1I.S. Departmer f Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety APR 26 2005 Mr. Charles Kimble NSWC Crane Division Ref. No. 05-0048 300 Highway 361 Crane IN 47522-5001 Dear Mr. Kimble: This is in response to your letter concerning the transportation of primary lithium batteries and cells aboard passenger aircraft in accordance with the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) adopted under Docket HM-224E (December 15, 2004). Specifically, you ask if the transportation of a sonobuoy which contains no more than the number of primary (non-rechargeable) lithium batteries necessary to power the intended piece of equipment, conforms to the requirement in Special Provision A102. The answer is yes. The HMR as amended by the HM-224E interim final rule, impose a limited prohibition on the offering for transportation and transportation of primary (non-rechargeable) lithium batteries and cells and equipment containing or packed with large primary lithium batteries as cargo aboard passenger-carrying aircraft. This interim final rule applies to both foreign and domestic passenger-carrying aircraft entering, leaving, or operating in the United States and to persons offering primary lithium batteries and cells for transportation as cargo on any passenger-carrying aircraft. A sonobuoy containing a primary (non-rechargeable) lithium battery may be transported in accordance with Special provision A102. In addition, Special provision A102(d) states that the net weight of the package (primary non-rechargeable lithium batteries) may not exceed 5kg. I hope this information is helpful. Please contact us if you require additional assistance Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 172.102 050048 173.183#

Page 2telertora §/72.102 PRIMAM 1093003 §173,185 Lithium Batteries 05-0048 r 2 MAR 2005 Ser 6074D/5037 FrOm: Commander, Crane Division, Naval Surface Varfare Center 30: Idward Mazzullo, Director of Hazardous Materials Standerds, PAMAS, Room 8430, 400 Seventh Street S.W., Maslington. DC 20590-0001 Subj: CFR CHANGES IN 173.185 (C) (4) AND SPECIAL PROVISION A102 D. Ref: (a) Federal Register / Volume 69, No. 240 (49 CFR Parts 171, 172, 173, and 175) dated December 15, 2004 (b) Discussion between Dale Hoit NSW Crane and Spencer Watson U.S. DOT RSPA on 10 Feb. 2005 1. Our office is requesting an interpretation of the CFR changes as provided in reference (a). issue is the interpretation of whether sonobuoys containing Per ref (b) the specific primaryrtithium bactepies meets the provision that allow Lithium Batteries Contained: in Equipment/to be transported as cargo aboard passenger cartying aircraft.t: 2. The sonobuoy meets the provisions in ref fa) Section: IV €. '38 Batteries Shipped incor with Equipment that allow for tranuportation a cargo aboard passenges carrying aircraft:of primary Dithtun batterieo. c/Theugonobuoy complies withe (1) , requirements and limitations ot 173.185 (0): 12) is packed in strong packaging; 1) conteins only the, necessary number ot total net: weight of che primary lithium batteries in the package prary achim pacercies co power the sonobuoy: and (4) the does not exceed 5 kg. In ref 172.102 Special provicion A102; a primary lithiun battery (a) Section VIT List of Subjects: contained in equipment is forbirden for transport aboard a passenger carrying aircraft unless: a. The battery complies with the requirements aud limitations of 173.185 (c); b. The package contains no more chat: the pantor of dithim batteries necessary to power the apirpertee. She eqoigment, containing the battery is pacher in atropg backaginasand d The in 30/003:00.1 •st decembear whether Che not it to perhaps tepperoine "e only the veight of the obey timer. isi ex retorenced 10 173.385 (c) (4) "Mr: failove the intent was for the ely Dochose 10: is the hazardous itor his#

Page 3PRIMEON A102 D. 30X0 Die aRd aDo transported. The songbooys contain small trip bartese phat chloone meets the requirements of 173 185c bu do sonommoy itselt, which is where the batterero opted, seigh above the 5 kg specified requirement. 4. NSUC Come point of contact is Dale Hoit, Code 6074, telephone conm (812) 854-2093. CHARLES KIMBLE By direction#