{"operation":"document","citation":"08-0305","title":"Elpro Services, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-01-16","effective_on":null,"summary":"08-0305 response to Elpro Services, Inc. concerning 173.185, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0305.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0305.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0305","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080305.pdf","body":"<<>>\n\nU.S. Department\nof Transportation Pipeline and Hazardous Materials\nSafety Administration\nJAN 7 6 2009 Washington. DC 20590\n1200 New Jersey Ave., SE\nMr. Martin Peter\nElpro Services, Inc.\nLangaeulistrasse 62\n9470 Buchs Switzerland\nRef. No.: 08-0305\nDear Mr. Peter:\nThis is in response to your letter dated December 1 1,2008 concerning the applicability of\nthe Hazardous Material Regulations (HMR; 49 CFR Parts 17 1-1 80) to small lithium\nmetal batteries contained in equipment. Specifically, you request a letter confirming your\nconclusions that these devices meet the requirements of 5 172.102(c), Special Provision\n(SP) 188.\nIn your letter, you described temperature monitoring devices that incorporate small,\nprimary lithium batteries and provided information on each type of battery including\nlithium content and compliance with applicable regulatory standards. You indicated the\ndevices are used to monitor temperature-sensitive products, many of which are\npharmaceuticals. You described a typical device as containing one battery embedded\ninto a monitoring device and sealed in a solid case. Each production lot of temperature\nmonitoring devices is subjected to a drop test in all directions fiom a height of 1 meter\nonto a solid concrete floor. A temperature monitoring device may be attached to a pallet\nor package, placed inside a package, or built into a packaging.\nYou indicated there is some confusion as to whether temperature monitoring devices are\nacceptable for transportation on aircraft by the HMR. Lithium cells and batteries\ncontained in equipment that meet the requirements of SP 188 are not subject to any other\nrequirements of the HMR by any mode of transportation, including aircraft. A person\nwho offers for transportation small lithium cells or batteries contained in equipment\nunder SP 188 must ensure that the cells or batteries comply with each of the requirements\nof SP 188.\nThe requirements in SP 188 of the HMR applicable to small lithium cells and batteries\ncontained in equipment are as follows:\n(1) The lithium content is limited to I gram per cell or 2 grams per battery; (2) the\nequipment must contain no more than 5 kg (1 1 lbs) of batteries and contain no more than\nthe maximum number of batteries necessary to power the piece of equipment; (3)\neffective October 1,2009, each cell or battery must be of a type proven to meet the\n\n<<>>\n\nrequirements of each test in the UN Manual of Tests and Criteria; and (4) the batteries\nand equipment containing the batteries must be packaged in a manner which precludes\nsparks or the evolution of a dangerous quantity of heat.\nUnder 173.22 of the HMR, it is the shipper's responsibility to properly class a\nhazardous material. Such determinations are not required to be verified by this Office.\nHowever, based on the information included with your letter, it is the opinion of this\nOffice that your product contains a single lithium metal battery containing less than 1.0\ngram of lithium and the device is unlikely to generate sparks or a dangerous quantity of\nheat.\nYou should also note the Federal Aviation Administration may require evidence that this\ndevice will not cause interference with the navigation or communication system of the\naircraft on which it is to be used. The documents attached are for your future reference\nregarding how the FAA handles devices1 batteries aboard aircraft.\n1 trust this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nUP\nEdward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\n\n<<>>\n\nPage 1 of 1\nFrom: Mazzullo, Ed \nSent: Thursday, December 11, 2008 4:08 PM\nTo: Drakeford, Carolyn \nCc: Betts, Charles ; Gorsky, Susan ; Kelley, Shane \nSubject: FW: Request for Assessment: Lithium Batteries in Temperature Monitoring Devices\nAttachments: 08121 1 Letter to DOT.pdf; CE-Deklaration Libero.pdf; Minamoto IVlaterial safety\nspecifications-MSDS-ER-battery.pdf; Tadiran Battery specification-pdc06engSL-761 .pdf;\nTeam LIBERO technical specs.pdf; Technical Note Tadiran.pdf\nFrom: Martin Peter [mailto:martin.peter@elpro.com]\nSent: Thursday, December 11, 2008 5:22 AM\nTo: Mazzullo, Ed \nCc: Sylvain Riendeau; Kaspar Frick\nSubject: Request for Assessment: Lithium Batteries in Temperature Monitoring Devices\nDear Mr. Mazzullo,\nThis week I have been forwarded a letter (email) from you to Mr. Henry Ames at Sensitech where you assess the\ncompliance of Sensitech's temperature monitoring devices with the relevant regulations. Similar to Sensitech,\nElpro is a company developing, producing and marketing temperature monitoring devices globally for the\npharmaceutical industry. The current discussion around the interpreation of the regulation by airlines in regards to\ntransporation of pallets containing temperature loggers powered by lithium batteries is causing major discussions\namonts the pharmaceutical industry - especially in the USA but increasingly also in Europe and Asia.\nAttached to this mail you find a letter summarizing our request and position as well as the relevant attachments to\nsupport our position.\nPlease no not hesitate to call me in case you have questions or comments.\nKind Regards,\nMartin Peter\nMartin Peter\nELPRO-BUCHS AG\nLangaeulistrasse 62\n9470 Buchs Switzerland\nTel: +41 (0) 81 750 03 11\nMob: +41 (0) 79 307 03 65\nFax: +41 (0) 81 750 03 17\nmartin,eeter@e!~ro,com I htt~./!zw,elelo~.c.~m\nLibero PDF-Logger: htt~://www.pdf-dataIouqer.com\nOnline-Man itoring: htt~:!!~~.~,elpro!og~.c9m!e!~~o~d.e.m.o\n\n<<>>\n\nELPRO-BUCHS AG Langaulistrasse 62 T +41 (0)81 750 03 11 ~ . e l p r o . c o m\nCH - 9470 B U C ~ S SG F +41 (0)81 750 03 17\nSwitzerland e swissQelpro.com ~unur, ASSURED ISO 9001\nU.S. Department of Transportation\nEdward T. Mazullo\nDirector, Office of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nWashington, DC 20590\nRequest for Assessment of Elpro's Temperature Monitoring Devices in regards to compliance with HMR; 49\nCFR Parts 17 1 - 180 and the Special Provisions (SP) 1 88 of 5 172.102(c)(l).\nSimilar to Sensitech, which you recently issued your assessment of their temperature monitoring devices in\nregards to above mentioned provisions, Elpro is manufacturing and marketing temperature monitoring\ndevices internationally used for Cold Chain Monitoring of pharmaceuticals transported via air-cargo (and\nother means of transportation):\nProduct Name\nLibero Ti 1\nLibero Ti1 -5\nLibero Ti1 -L\nLibero Til-D\nLibero Tel-N\nLibero Tel-P\nLibero THi1 Manufacturer, type & amount\nof Lithium per battery\nMinamoto, Li-SOCI2, 0.789\nMinamoto, Li-SOCI2, 0.789\nTardian, Size AA, 0.559\nTardian, Size AA, 0.559\nTardian, Size AA, 0.559\nTardian, Size AA, 0.559\nTardian, Size AA, 0.559 Function of product (for details see attached \"Team\nLIBERO technical specs 3\nTemperature monitoring, internal sensor\nTemperature monitoring, internal sensor\nTemperature monitoring, internal sensor\nTemperature monitoring, internal sensor\nTemperature monitoring, external sensor\ng\nTemperature & humidity monitoring, internal sensors\nEach device contains one battery only. All above mentioned batteries are primary lithium batteries and they\ncomply with the standards SP 188 and UN Manual of Tests and Criteria as:\nBoth battery types used contain >>\n\nThe Source of Electric Power\nMINAMOTOB MINAMOTO BATTERY LTD.\nFlat A-6, SF., Mai Hing Industrial Building, 16-18 Hing Yip Street, Kwun Tong, Kowloon, Hong Kong.\nTel: (852) 2793 4790 Fax: (852) 2793 4932 e-mail : info@minamoto.com\nMaterial Safety Data Sheet\n(form according to EEC Directive 9311 121EC)\nI 1. Identification of the product and supplier\nldentification of the product: Lithium, Thionyl Chloride (Li-SOC12)\nnotwechargeable batteries\n1 2. Composition and information about the ingredients 1\nActive materials\nLithium (Li)\nCarbon black (C)\nThionyl chloride (SOCL2)\nLithium aluminum tetrachloride\n(Li AICM)\nI Weight grams -I\n0.78\n0.62\n5.9\n0.77\n-\nPassive materials\nBase Metal\n1 other&\nWeight grams\nSteel\n8.3\nPlastic 0.7\nI\nGlass fiber\n0.4\n- p~\n1 3. Hazards identification\nThe lithium-thionyl chloride batteries are not hazardous when used according to the\nrecommendations of the manufacturer.\nBut if the design of the circuit doesn' t forecast all the necessary cares to prevent the\ninversion of polarity in the assembly of the battery or the battery bt packs, there is the risk\nof dangers due to the explosion of the battery.\nDefine with care the assembling process to assure that accidental short circuit don' t\nhappen.\nDo not expose the batteries to temperatures above 100°C.\n- Page 111 -\n\n<<>>\n\nIf the battery lose its integrity and sealing, due to break or damages (mechanical, thermal\nor electrical), leakage, explosion or fire may follow.\nIn this case there is the risk of release of chemical materials as defined in the paragraph 2\n(active materials) of this safety sheet.\nHere below are shown the nature of special risks and the advices of caution.\nNature of special risks\nR14115 (reacts with water and yields flammable gases)\nR21 (harmful in contact with skin)\nR22 (harmful if swallowed)\nR35 (causes severe burns)\nR41 (risk of serious damage to the eye)\nR42143 (may cause sensitation by inhalation and skin contact)\nSafety advices\nS2 (keep out of reach from children)\nS8 (keep away from moisture)\nS22 (do not breathe dust)\nS24 (avoid contact with skin)\nS26 (in case of contact with eyes, rinse immediately with plenty of water and seek medical\nattention)\nS36 (wear suitable protective clothing)\nS37 (wear suitable gloves)\nS43 (in case of fire use extinguisher type D. DO NOT USE WATER)\nS45 (in case of incident or indisposition seek medical attention)\n1 4. First aid measures\nOnly in case of contact with internal components of the battery:\nSkin contact: Eye contact: Inhalation: Ingestion: flush with plenty of water\nflush with plenty of water (eyelids held open)\nbreath fresh air and give oxygen or artificial respiration by specialist people\ndrink much water and consult a doctor\nI 5. Fire-fighting measures\nExtinguishing media: extinguishers type D, Lith-X, DO NOT USE WATER in case\nof battery leakage\nSpecial hazards: irritating vapour\nSpecial protective\nequipment: wear protective clothing, use self-contained breathing apparatus\nwith filtered cartridge type ABEK\n- Page 212 -\n\n<<>>\n\n1 6. Accidental release measures\nIn case of break of a battery, all the people must go away from the place where the\nincident happened and come back only after the dissolution of the irritating gas.\nBroken batteries or battery packs must be covered with sodium carbonate (Na2C03) or dry\nsand, place them in approved container and dispose in accordance with local regulation.\nFor the eventual handling use gloves in VitonB.\n1 7. Handling and storage\n7.1 Handling: - Do not recharge\n- Do not use different types and brands of batteries or with different state\ncharge\n- Avoid short circuit\n- Use desk of work electrically insulated\n- Avoid to work over wet surface\n- Use plastic calibre to valuate the dimensions of a Lithium battery or to\ninsulate the metallic surface of the battery\n- Do not have rings on the fingers; otherwise wear insulating gloves.\n- Do not cut in the same time both the terminals of a battery: it could be a\nshort circuit trough the shears\n- Keep the batteries in nonconductive trays (i.e. plastic, wood or carton)\n- Do not solder directly on the battery\n- Do not disasserr~ble the batteries, do not throw them in the fire, do not\nhole, do not overheat or plunge into water\n7.2 Storage: - Store the Lithium cells in a cool, dry and ventilated area far from fires and\nheating sources.\n- It is recommended the use of a noncombustible structure, keep adequate\nclearance between walls and batteries.\n- The maximum temperature suggested for the storage is +30° C\n- Higher temperatures are allow but cause an increase in the self discharge\nof the battery and speed up the process of passivation\n- in any case, never go over 100 \"C, as the batteries can break and cause\na leakage\n- Arrange adequate protections to avoid possible hurts to the batteries\n- Keep the batteries in their original packages till when they are used\n- Do not expose the batteries directly to the sun light\n- Do not put an higher number of cartons one on another (respect what\nindicated)\n- If in the same place are storage batteries with a total capacity\n> 50,000 Ah, it is suggested to install an alarm for smoke and gas\n- Page 313 -\n\n<<>>\n\n1 8. Exposure controlslpersonal protection\nIf the battery is integral, storage and handle with care, there is any dangers.\nIt is suggested to handle the batteries in a ventilated place, to don' t smoke, eat or drink\nduring the assembling.\n1 9. Physicalaand chemical properties\nAppearance: The battery ER34615M is a metal cylinders with diameter 34,2mm and height\n61,5 mm, fitted with an external plastic sleeve.\n10. Stability and reactivity\n10.1 Conditions to avoid:\nDo not expose at temperature higher than 100\" C.\nAvoid short circuit, crush, exposition to heat sources.\nDo not disassemble the batteries or the battery packs, do not throw them in the fire, do not\nperforate them, do not overheat or wet them.\n10.2 Material to avoid:\nWater, oxidizing agents, alkalis.\nI 1 I. Toxological information I\nThe rupture of a lithium-thionyl chloride batteries can developed the following substances:\n- Hydrogen (H2), lithium Oxide (Li20) and lithium Hydroxide (LiOH) in case of reaction of\nlithium metal with water\n- Chlorine (Clz), sulfur dioxide (S02) and disulfur dichloride (S2C12) if the thionyl chloride\ngo above 140,5\"C\n- Hydrochloric acid (HCI) and sulfur dioxide (S02) in case of reaction of thionyl chloride\nwith water\n- Hydrochloric acid (HCI), lithium oxide (LizO), lithium hydroxide (LiOH) and aluminium\nhydroxide (AI(OH)3) in case of reaction of lithium thetrachloroaluminate with water.\n1 12. Ecological information\nWhen properly used or disposed, the lithium-thionyl chloride batteries do not present\nenvironmental hazard.\nI 13. Disposal consideration\nFor the disposal apply to specialized organisation.\n- Page 414 -\n\n<<>>\n\n1 14. Transport information\nRestriction for the transport: class 9 in accordance to the United Nation regulation.\nInternational convention\nRoad transport: not hazardous in accordance to ADR\nRail transport: not hazardous in accordance to RID\nSea transport: not hazardous in accordance to INlDG\nAir transport: not hazardous in accordance to ICAO\nNote: the batteries which contain few than 0,5g of metal lithium are not restricted for\ntransport.\n1 15. Regulation information\nThe transport of lithium batteries is regulated by ONU as described in the\n\" Recommendations of the Transport of Dangerous Goods ref.STISG1AC. 1011 -Ed.-1 I -\n2000\" .\nDepending on their lithium metal content (quantity higher than 0,5g), the batteries may or\nmay not be assigned to the transport restrictions, following the rules defined in the ONU\ndocument \" Recommendations of the Transport of Dangerous Goods\".\n1 16. Other information\nThe lithium-thionyl chloride batteries or battery packs must be handle by specialize people.\nThey must be kept out of reach from children.\nThey must be used following the Technical Specifications, without exceed the values\ndefined.\nDo not assemble by one self a serial of batteries, but request the finished battery to the\nsupplier, who will provide for install protection components (diodes, etc..)\nThe information contained in this sheet are based on the present knowledge and the\nconditions of use.\nFor every use not in conformity to the safety sheet or for the use in combination with any\nother material or in any other process the user is the responsible.\nThe responsible of the products\n- Page 515 -\n\n<<>>\n\nTadiran Batteries GmbH\nIndustriestr. 22\nD-63654 Budingen\nTel. +49(0)6042/954-0 www.tadiranbatteries.de\nTADIRAN\nBATTEXKKES\nKeyword:\nLithium Xtra\nModel: SL-761 WARNING:\nFire, explosion, and severe\nburn hazard. Do not\nPerformance Data Size %AA recharge, disassemble,\n(Typical values for batteries stored at 25°C for one year) heat\nincinerate, or expose\nSvstem LiISOCI. contents to water.\nNbmina~ voltage\nNominal capacity\nUL recognition under\nfile MH 12827\nNominal current\nMax. continuous discharge current 30 mA\nPulse current capability 90 mA See also our website\nAnode surface area 9 cm2 under ProductsISafety\nLithium content 0.5 g\nWeight 12 9\nVolume 5.7 cm3\nTemperature range -55...+85 \"C\nTypical Discharge Curves at +25\"C\n4.0 L I\n0.0 t-L I ''''111 ' ' \"\"\"l ' '\"1\"11 ' 1\"'11'1 ' ' 1\"1111 I ' \"LUJ\n0.1 i 10 102 l o 3 l o 4 105\nTime hours\nAvailable Capacity\n1.6 r I I I I 1\n0.15 thick\nCurrent ImA\nOperating Voltage\n-50 -35 -20 -5 10 25 40 55 70 85 100\nTemperature /\"C\nPulse Discharge Characteristics at +25\"C\n0.2 thick 0.2 thick\n4.0\n3.5\nAvailable Terminations Catalogue No. Any values given here are\nfor information purposes\nSL-7611s Standard 11 1 07611 00 only. They also depend on\nSL-761n Tags 1 1 1 0761 2 00 actual conditions of use\nSL-761lP Pins 11 1 07613 00 and are not warranties of\nSL-761 IPR Pins Radial 11 1 07616 00 future periormance.\nSL-761lPT Polarized Tags 11 10761800 Subject to change.\n0.0\n0 200 400 600 800 1 0 0 0 ~\nTime /hours f\n\n<<>>\n\nTeam LIBERO - Technical Specifications\nPicture\nTYPe\nPart number\nApplication area\nRecord options\nRecord mode\nProbe type\nMeasurement range\nAccuracy\n- -\nMobile Temperature 1 ~ e m ~ e r a t u F & Humidity Data ~ 0 ~ ~ ; s\n4510 1 4511\n45 12\n45 13\n4514\n4515 ) 4516\nSupply chain tem~erature monitorina 1 Standard 1 Tem~erature I Temperature ( Liquid Nitrogen I Supply chain\n. . . >\ntemperature\nmon'itoring for\nmonitoring for and cooling cabi- temperature &\nmonitoring,\ndry ice shipments\ndry ice shipments\nDT1 successor\nmonitoring\nMultiple use\nStartlstop mode or\nLoop mode\nInternal NTC probe\nSingle use\nStaNstop mode\nonly\nMultiple use\nStart/stop mode or\nLoop mode\nSingle use\nStart/stop mode\nonly\nMultiple use\nStartlstop mode or\nLoop mode\nLIBERO NTC probe\nwith connector,\ncable length 50 cm\n3094-LL005: 90.-\no r 3 m\n3094-LLO3: 130.-\nLIBERO PTlOO\nprobe with\nconnector, cable\nlength 50 cm\n31 63-LL005: 180.-\nCombined internal\nprobe TlrH\n-\n-35..70 \"C 1 -35..70 \"C -35..70 \"C -80..70 \"C -80..85 OC -200..200 O C -35..70 \"C\n0..100 %rH\n-1Oo..25\"C +I-0.2'\n25\"..7OoC +I-0.5\" 25\"..2OO0C +/-1.0\" 25\"..70°C +/-I .OD\n25\"..70°C +I-0.5\" -loo..-200°C +I-1.0\" OD..-35°C +/-I .O0\n-loo..-35°C +/-0.5\" -1 O0..-35°C +/-0.5\" t0%..90% rH +I- 2%\n-3S0..-80°C +/-I .go 0%..10%% rH +/- 3%\n90%..100% rH +/- 346\nResolution 1 1/10°\n.. . -\nMemory capacity\n16'000 measuring data points Programmable measurement interval\nand display renewal\nminute or more, programmable\n1 8'000 each\n- --\nMarketing I AR\nTeam Libero - Technical Specifications - Prices and specifications are subject to change without notice!\nOctober 15, 2008\n\n<<>>\n\nP.O. BOX 1\nTADxRAN & KIRYAT EKRON\nBATTERIE S D ~ ~ 7 ~ 7 ~ ~ $ 4 4 4 5 0 3\nFAX: (972-8) 9413079\nSee us on the web: www.tadiranbat.com\nGuidelines for shipping Lithium Batteries\n1. Scope\nThis document is about the new UN regulations for transportation of lithium cells\nand batteries as detailed in the Model Regulations on the Transport of Dangerous Goods\nRef STISGIAC. 10-1 Revisi0.n 12-2001 (UN 3090). The regulations also cover the IATA,\nICAO, and ARD requirements.\nTransportation in the USA is subject to CFR49, which does not yet include the new LJN\nregulations. The change to the new UN regulations in the USA is expected on the third\nquarter of 2003. Therefore, shippers in the USA can stay now with the current\ntransportation regulations, except when transporting out of the USA. In this case,\nshippers have to comply with the new UN regulations.\nThe following guidelines impart an immediate, basic working knowledge for\nshipping Tad.iran Lithium Batteries and Cells safely and legally. This information should\nbe viewed only as a guide to existing regulations and not a regulation in and of itself.\n12. Shipping Methods\nThe shipping method is determined by the amount of lithium in a cell or a battery.\nThe shipping regulations define two groups.\n- Non-Restricted\n- Class 9\n2.1 Non-Restricted fi 3090 defined as non-restricted, all cells that have less than one gram of lithium\nand all batteries that have less then two grams of lithium. Provided that each cell and\neach battery passed successfully the tests per UN specification; (Recommendation on the\nTransport of Dangerous Goods, Manual of Test and Criteria, paragraph 38.3).\nA list of Tadiran products with the amount of lithium in each product is presented\nin Appendix # 1.\nShipping of non-restricted articles requires the cells and the batteries to be separated in\nsuch a way to prevent short circuit, and they must be packed in strong packaging, except\nwhen installed in equipment.\nExcept when installed in equipment, or for packages that contain more than 24 lithium\ncells or 12 lithium batteries they should comply with the following addition requirements\n\n<<>>\n\nP.O. BOX 1\nTADxmAN $ KIRYAT EKRON\nBATTERIES D 7 E ~ ~ ~ 7 ~ ~ ~ ) 0 ~ 4 4 4 5 0 3\nFAX: (972-8) 941 3079\n1 See us on the web: www.tadiranbat.com\n2.1.1 Each package must be marked indicating that it contains lithium batteries\nand that special procedures should be followed in the event that the package is damaged.\nSee Appendix # 2.\n2.1.2 Each shipment must be accompanied with a document indicating that the\npackages contain lithium batteries and that special procedures should be followed in the\nevent a package is damaged. See Appendix # 3\n2.1.3 Each package is capable of withstanding a 1.2 meter drop test in any\norientation without damage to cells or batteries contained therein, without shifting of the\ncontents so as to allow battery to battery (cell to cell) contact and without release of\ncontents.\n2.1.6 Except in the case of lithium batteries packed in equipment, packages may\nnot exceed 30Kg gross mass in all transportation modes air, sea and ground.\n1 2.2 class 9 I\nClass 9 (Restricted), are all cells that have more than one gram of lithium and all\nbatteries that have more then two grams of lithium, provided that each cell and each\nbattery passed successfully the tests per LTN specification: (Recommendation on the\nTransport of Dangerous Goods, Manual of Test and Criteria, paragraph 38.3).\nA list of Tadiran products with the amount of lithium in each product is presented in\nAppendix # 1.\nFollowing are the requirements for shipping of Class 9 articles.\n2.2.1 The maximum gross weight per a single package that carry Class 9\n(Restricted) articles is detailed below.\nModes of Transportation\nPassenger Airplane\nCargo Airplane\nSea\nGround\nGross Weight in Kg\n5\n35\nOver 35\nOver 35\n2.2.2 The completion of RESTRICTED ARTICALES CERTIFICATION from\nDeclaration for Dangerous Goods Form) in according with detailed instruction\nmanual. This document must be carefully typewritten with no mistake,\nor corrections, and can only be signed by legally certified person.\n2.2.3 Enclosing an International Airway Bill.\n2.2.4 Enclosing three copies of commercial invoice.\n\n<<>>\n\nP.O. BOX 1\nTAD1 RAN $ KIRYAT EKRON\nISRAEL 70500\nB*TTE-ES I, TEL: (972-8,9444503\nFAX: (972-8) 9413079\nSee us on the web: www.tadiranbat.com\n2.2.5 Proper packaging: The outer packaging must be Group I1 package such as\nfiberboard box (specified number is 4G) with proper UN specs marks on the carton\n(sturdy shipping cartons meeting UN Performance specification testing).\n2.2.6 Labels:\n- Class 9 label\n- \"Cargo Aircraft Only\" label when shipped by cargo aircraft.\n- Label stating company name, address\n- The following statement, must appear on the carton:\nLithium Batteries\nUN NBR 3090 CLASS 9\nPkg. Inst. 903 I1\nS.T.C\nGross weight in ------------ Kg\nPACK NO .-------- OF ----------\nF\note: For shipment to USAICANADA a 24hour phone number available to call in event\nfan emergency, must be included in the shipping documents.\n4. Over pack\nOver pack: An enclosure used to provide protection or convenience in handling o\npackage or to consolidate two or more packages. The package being over packed must\ne eligible to be transported by itself, and properly prepared for shipment with proper\narking and labeling. The marking and labeling on each of the packages being over\nacked must be reproduced on the outside of the over pack unless visible from outside of\nPackage: The end result of the packaging process, which includes all the\nazardous content, and all of the packaging properly closed and prepared for proper\narking and labeling.\n5. Training\nSA employees involved in packaging or shipment of Class 9 batteries must complete a\nFR 49 certified hazardous material shipping training course. The certification should be\nenewed every three years. In face of the new revision, it is strongly recommended that\nhe employees also complete the IATA training course\ni\n\n<<>>\n\nP.O. BOX 1\nTADxRAN $ K1RY.T EKRON\nISRAEL 70500\nBATTEICIE TEL: (972-8) 9444503\nFAX: (972-8) 9413079\nSee us on the web: www.tadiranbat.com\n6. Violations of shipping regulation rules\nkViolation of the US DOT HMR (Hazardous Material Regulation) is subject to a\nme of up to$27,500. Multiple fines may be imposed for a single shipment for each type\n\n<<>>\n\nP.O. BOX 1\nTADxmAN $ KIRYAT EKRON\nISRAEL 70500\nTEL: (972-619444503\nFAX: (972-8) 9413079\nSee us on the web: www.tadiranbat.com\nu\nI TECHNICAL NOTICE i\ni\nAppendix # 1, Quantity of lithium metal in Tadiran cells and Batteries\n\n<<>>\n\nAppendix# 2, label for package with non-restricted cells or batteries\na -,=m CAUTION !\nLithium Batteries inside\nFlammable if damaged\nHandle with care\nif package is damaged,\nbatteries must be quarantined,\ninspected and repacked.\nFor emergency information, call:\n1-800424-9300\n\n<<>>\n\nP.O. BOX 1\nTADIRAN & KIRYAT EKRON\nBATTERIES D ~E~7~7~0,\"~g\"444503\nFAX: (972-8) 9413079\nSee us on the web: www.tadiranbat.com\nAppendix # 3, example of shipping document for non-hazardous cargo\nShippers Certification for Non-Hazardous Cargo\nAWB No. A l r p o r t o f Dep.\nI I I\nThis is t o c e r t l f y t h a t t h e artlclesfsubslences of this shipment a r e p r o p e r l y\ndescribed b y name, t h a t t h e y are n o t listed i n t h e c u r r e n t edition o f I A T A\nDangerous Goods Regulations ( D G ~ ) . Alphabetical Llst a? Dangerous Goods,\nno'r d o they correspond t o a n y of the hazard classes appearing in the DCR,\nSectian 3, classificatlon o f Dangerous Goods and t h a t t h e y are known t o be\nn o t danqerous, 8.e. not restricted. Furthermore the Shipper confirms t h a t\nthe goods a r e in proper condition for transportation o n passenger c a r r y i n g\naircraft.\nMarks a n d\nNumber of\nPackages\nProper Description o f Goods\n(Tradel'Narnes not Permitted)\nSpecify each article separately\nNet quantity\np e r package\n. . ..-.. .\nName a n d Address o f Shipper\nSignature\n'To-be completed in duplicate:'' 7Distribution: One copy t o accompany the A W B\n\" \" to b e filed a t airport o f departure [ w i t h AWB-copy) I\n\n<<>>\n\nP.O. BOX 1\nTADI[RAN $ KIRYAT EKRON\nBATTElRIE S D ~E~7~7~0~~~444503\n~ -- I - - - * - ~ - -\nFAX: (972-8) 941 3079\nSee us on the web: www.tadiranbat.com\nAppendix # 4, shipper declaration for Dangerous Goods, (Class 9)\n\n<<>>\n\nP.O. BOX 1\nTAD1 RAN $ KIRYAT EKRON\nISRAEL 70500\nBATTE-E * TEL: ,9724,9444503\nFAX: i972-8j 9413079\nSee us on the web: www.tadiranbat.com\nr Appendix # 5 label for package with Class 9 (restricted) cells or batteries\nNote: The above label will be used when goods have to be shipped with Cargo Airplanes only.\nLithium Batteries\nUN NBR 3090 CLASS 9\nPkg. Inst. 903 I1\nS.T.C\nGross weight in ------------ Kg\n\n<<>>\n\nLTN 11111\n10 of 10\n\n<<>>\n\nAdvisory\nCircular\nSubject: Use of Portable Electronic\nDevices Aboard Aircraft\nDate: 8/25/06\nAC No: 91-21.1B\nInitiated by: AFS-350\n1. PURPOSE. This advisory circular (AC) provides aircraft operators with information and guidance\nfor assistance in compliance to Title 14 of the Code of Federal Regulations (14 CFR) part 91,\nsection 91.21. Section 91.21 was established because of the potential for portable electronic devices\n(PED) to interfere with aircraft communications and navigation equipment. It prohibits the operation\nof PEDs aboard U.S.-registered civil aircraft while operating under instrument flight rules (IFR). This\nrule permits use of specified PEDs and other devices that the operator of the aircraft has determined\nwill not interfere with the safe operation of that aircraft. The recommendations contained herein are\none means, but not the only means, of complying with section 91.21 requirements, pertaining to the\noperation of PEDs.\n2. CANCELLATION. AC 91-21.1A, Use of Portable Electronic Devices Aboard Aircraft, dated\nOctober 2, 2000, is canceled.\n3. RELATED 14 CFR SECTIONS. Section 91.21, 121.306, 125.204, and 135.144.\n4. BACKGROUND.\na. Section 91.21 (formerly section 91.19) was initially established in May 1961 to prohibit the\noperation of high-frequency omnidirectional range was being used for navigation purposes. The\nFederal Aviation Administration (FAA) subsequently determined that other PEDs could be potentially\nhazardous to aircraft communication and navigation equipment, if operated aboard aircraft.\nAmendment 91-35 amended the scope of former section 91.19 to prohibit the use of additional PEDs\naboard certain U.S. civil aircraft. Section 91.21, as adopted, was drafted to require the air carrier or\ncommercial operator to determine whether a particular PED will cause interference when operated\naboard its aircraft.\nb. RTCA Special Committee 156 accomplished a study of the potential for interference from\nPEDs and released Document No. RTCA/DO-199, volumes 1 and 2, entitled “Potential Interference to\nAircraft Electronic Equipment from Devices Carried Aboard.” RTCA Special Committee 177 did a\nfurther study of these devices and released Document No. RTCA/DO-233, entitled “Portable\nElectronic Devices Carried on Board Aircraft.” The finding and conclusions from these two studies\nhelped the FAA establish the current policy which allows the use of non-transmitting PEDS during\nnon-critical phases of flight. In March 2003, the FAA requested that RTCA form a special committee\nto evaluate and develop guidance related to assess the impact and risks related to the use of\n\n<<>>\n\nAC 91-21.1B 8/25/06\nintentionally radiating PEDs (transmitting PEDs, or T-PEDs) that passengers may bring onto civil\naircraft. These include mobile telephones, computers with wireless network capabilities, and other\nwireless-enabled devices such as Personal Digital Assistants (PDA). On October 19, 2004, RTCA\nreleased Document No. DO-294, prepared by Special Committee 202, titled “Guidance on Allowing\nTransmitting Portable Electronic Devices (T-PEDS) on Aircraft” (to obtain RTCA documents see\nparagraph 8b).\nc. Other activities in this area were done by the Consumer Electronics Association when in\nOctober, 2004; they issued a standard practice to help manage the use of wireless devices on board\naircraft that would greatly enhance the flightcrew and the flying public’s ability to comply with airline\npolicies for portable electronic devices.\n5. DISCUSSION.\na. The related 14 CFR sections in paragraph 3 allow for the operation of PEDs that the operator of\nthe aircraft has determined will not interfere with the navigation or communication system of that\naircraft. In addition to the originally addressed non-transmitting PEDs, this revised AC also recognizes\nand provides guidance on the potential use of T-PEDS. It should be noted that the responsibility for\npermitting passenger use of a particular PED technology lies solely with the operator. RTCA/DO-233,\ncurrent edition, provides government agencies and aircraft operators with recommendations for\nacceptable use of certain non-transmitting PEDs onboard aircraft. The current edition of\nRTCA/DO-294 identifies a process for airlines to make a determination of acceptable use of T-PEDs.\nThe determination of an interfering effect caused by a particular device on the navigation and\ncommunication system of the aircraft on which it is to be used or operated must, in case of an aircraft\noperated by the holder of an air carrier certificate or other operating certificate, be made by that\noperator (i.e., certificate holder). In all other cases, a determination must be made by the operator\nand/or by the pilot-in-command (PIC). In some cases, the determination may be based on operational\ntests conducted by the operator without the need for sophisticated testing equipment.\nb. When safely at cruise altitude, the pilot could allow the devices to be operated. If interference\nis experienced, the types of devices causing interference could be isolated, along with the applicable\nconditions recorded. The device responsible for the interference should then be turned off. If all\noperators collect this type of data with specific information, a large enough database could be\ngenerated to identify specific devices causing interference. The operator may want to obtain the\nservices of a person or facility capable of determining non-interference to the aircraft’s navigation,\ncommunication, or other electronic system. Personnel specifically designated by the air carrier or\ncommercial operator for this purpose may make this determination using the process described in\nRTCA/DO-294. For other aircraft, the language of the rule expressly permits the determination to be\nmade by the Pilot in Command or operators of the aircraft. Thus, in the case of rental aircraft, the\nrenter-pilot, lessee, or owner-operator could make the determination.\n6. RECOMMENDED PROCEDURES FOR THE OPERATION OF PEDs ABOARD\nAIRCRAFT. If an operator allows the use of PEDs aboard its aircraft, procedures should be established\nand spelled out clearly to control their use during passenger-carrying operations. The procedures, when\nused in conjunction with an operator’s program, should provide the following:\na. Methods to inform passengers of permissible times, conditions, and limitations when\nvarious PEDs may be used. This may be accomplished through the departure briefing, passenger\nPage 2 Par 4\n\n<<>>\n\n8/25/06 AC 91-21.1B\ninformation cards, captain’s announcement, and other methods deemed appropriate by the\noperator. For air carrier operations conducted under 14 CFR part 121 or part 135, the\nlimitations, as a minimum, should state that use of all such devices (except certain inaccessible\nmedical electronic devices, for example, heart pacemakers) are prohibited during any phase of\noperation when their use could interfere with the communication or navigation equipment on\nboard the aircraft or the ability of the flightcrew to give necessary instructions in the event of an\nemergency.\nb. Procedures to terminate the operation of PEDs suspected of causing interference with\naircraft systems.\nc. Procedures for reporting instances of suspected or confirmed interferences by a PED to a\nlocal FAA Flight Standards District Office or the FSDO that has certificate management\nresponsibility for the air carrier.\nd. Cockpit to cabin coordination and cockpit flightcrew monitoring procedures.\ne. Procedures for determining non-interference acceptability of those PEDs to be operated\naboard its aircraft. Acceptable PEDs should be clearly spelled out in oral departure briefings and\nby written material provided to each passenger to avoid passenger confusion. The operator of\nthe aircraft must make the determination of the effects of a particular PED on the navigation and\ncommunication systems of the aircraft on which it is to be operated. The operation of a PED is\nprohibited, unless the device is specifically listed in section 91.21(b)(1) through (4). However,\neven if the device is an exception from the general prohibition on the use of PEDs, an operator\nmay prohibit use of that PED. The use of all other PEDs is prohibited by regulation, unless\npursuant to section 91.21(b)(5). The operator is responsible for making the final determination\nthat the operation of that device will not interfere with the communication or navigation system\nof the aircraft on which it is to be operated.\nf. Prohibiting the operation of any PEDs during the takeoff and landing phases of flight. It\nmust be recognized that the potential for personal injury to passengers is a paramount\nconsideration, as well as is the possibility of missing significant safety announcements during\nimportant phases of flight. This prohibition is in addition to lessening the possible interference\nthat may arise during sterile cockpit operations (below 10,000 feet).\n7. CELLULAR & ONBOARD TELEPHONE SYSTEMS.\na. T-PEDs have considerations in addition to those listed in paragraph 6. These include cellular\ntelephones, citizens band radios, remote control devices, computers with wireless network capabilities,\nand other wireless-enabled devices such as PDAs, etc. The Federal Communications Commission\n(FCC) currently prohibits the use of cell phones while airborne. Its primary concern is that a cell phone,\nused while airborne, would have a much greater transmitting range than a land mobile unit. Their use\ncould result in unwanted interference to transmissions at other cell locations since the system uses the\nsame frequency several times within a market or given operating area. Since a cell phone is capable of\noperating on various cellular frequencies, unwanted interference may also affect cellular systems in\nadjacent markets or operating areas.\nPar 6 Page 3\n\n<<>>\n\nAC 91-21.1B 8/25/06\nb. The FAA supports this airborne restriction for other reasons of potential interference to aircraft\nsystems and equipment. Currently, the FAA does not prohibit the use of certain cell phones in aircraft\nwhile on the ground. An example might be their use at the gate or during an extended wait on the\nground while awaiting a gate, when specifically authorized by the operator. A cell phone will not be\nauthorized for use while the aircraft is being taxied for departure after leaving the gate. The unit will be\nturned off and properly stowed to prepare the aircraft for takeoff as per the operator’s procedures.\nWhatever procedures an operator elects to adopt should be clearly spelled out in oral briefings prior to\ndeparture or by written material provided to each passenger.\nc. Onboard telephone systems that are type accepted by the FCC as air-to-ground equipment, which\nhave been permanently installed in t","truncated":true,"body_characters":57291}