{"operation":"document","citation":"08-0052","title":"ILS Manager - Aircraft — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-03-26","effective_on":null,"summary":"08-0052 response to ILS Manager - Aircraft concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0052.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0052.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0052","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080052.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nMAR 2 6 2008\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Greg Hardwick\nILS Manager - Aircraft\n13350 US Highway 19 North\nClearwater, FL 33764\nRef. No.: 08-0052\nDear Mr. Hardwick:\nThis is in response to your letter dated February 26,2008, concerning requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80) applicable to the transportation\nof navigation equipment containing two lithium-thionyl chloride (Li-SOCL2) batteries. In your\nletter you reference existing letters of interpretation issued by this office (Ref. No.: 07-0055 and\n07-0202) and ask for a final interpretation that clarifies whether you should continue shipping\nyour navigation equipment as Class 9 material or begin shipping it as nonregulated. According\nto your letter, each Li-SOCL2 battery contained in the navigation equipment has a lithium\ncontent of approximately 1.7 grams.\nThe letters of interpretation you reference are both accurate. We a final rule entitled\n\"Hazardous Materials; Transportation of Lithium Batteries\" (HM-224C & HM-224E; 72 FR\n44929) on August 9,2007. The rule becomes effective on October 1,2008, but voluntary\ncompliance was authorized as of October 1,2007. Therefore, you may use the \"old\" or \"new\"\nrequirements until October 1,2008. This overlap accounts for the apparent differences between\nthe two letters. Letter no. 07-0055 discusses the requirements that are currently effective (old)\nand the requirements that will become effective on October 1,2008 (new), while letter no. 07-\n0202 focuses solely on the requirements that are currently effective (old). Copies of the\nrulemaking and letters are enclosed for your convenience.\nSince you are already transporting the navigational equipment as a Class 9 material, I suggest\nyou align your shipping practices with the August 9,2007 rulemaking in preparation for the\nOctober 1,2008 effective date. Please refer to letter of interpretation no. 07-0055 for additional\ninformation on shipping your navigational equipment.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely, ,-\n'Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\n---- Original Message-----\nFrom: PHMSA-Feedback [mailto:PHMSA-Feedback]\nSent: Tuesday, February 26, 2008 2:46 PM\nTo: HMIS <PHMSA>; PHMSA Web Initiative\nSubject: Feedback: Hazardous Materials Regulations Question\nPlease reference Hazardous Material Interpretations ID# 07-0202 and 07-0055.\nAs the Honeywell authority for transportation of Lithium batteries here at\nour Clearwater, EL facility, I would appreciate a final interpretation from\nyour office regarding the transportation of Lithium batteries contained in\nEquipment. Honeywell provides navigation equipment to the military all over\nthe world and delivers each item with two (2) medium ?C? size Primary\nLithium Thionyl-Chloride batteries, each with 1.79 Li contained in the\nequipment.\nFurther battery facts and transportation details are as follows:\n? The batteries are shipped as contained in the equipment and contain\nthe necessary number of batteries only to power the equipment\n? The battery and the navigation equipment are designed with the\nappropriate safety features ? diode or?ing to prevent reverse current flow,\nsafety vent, short circuit protection, etc.\n? Each battery when fully charged contains < 2.0 grams Li\n? The net weight of the batteries < 5kg\n? The battery vendor reports this battery to meet the UN Manual of Tests\nand Criteria\nAs the competent DOT authority for transportation of Lithium batteries\nHoneywell would appreciate your ruling on the proper shipping method of the\nLithium Battery Contained in equipment and if in fact they these batteries\ncan be shipped UN-Regulated or if we should continue shipping each item as a\nClass 9 material.\nThank You,\nGreg Hardwick\nHoneywell DSES - Clearwater\nILS Manager - Aircraft\nph. (727) 539-4890, fax (727) 539-4893\nemail: greg.hardwick@honeywell.com\n-----------\nGreg Hardwick\nAffiliation: Industry (Honeywell International)\n13350 U.S. Highway 19 north\nClearwater, Flo 33764\nPhone: 727-539-4890\nFax: 727-539-4893\nEmail: greg.hardwick@honeywell.com","truncated":false,"body_characters":4270}