# Elpro Services, Inc. — Hazardous Materials Safety Interpretation - **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:** Not available - **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:** <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration JAN 7 6 2009 Washington. DC 20590 1200 New Jersey Ave., SE Mr. Martin Peter Elpro Services, Inc. Langaeulistrasse 62 9470 Buchs Switzerland Ref. No.: 08-0305 Dear Mr. Peter: This is in response to your letter dated December 1 1,2008 concerning the applicability of the Hazardous Material Regulations (HMR; 49 CFR Parts 17 1-1 80) to small lithium metal batteries contained in equipment. Specifically, you request a letter confirming your conclusions that these devices meet the requirements of 5 172.102(c), Special Provision (SP) 188. In your letter, you described temperature monitoring devices that incorporate small, primary lithium batteries and provided information on each type of battery including lithium content and compliance with applicable regulatory standards. You indicated the devices are used to monitor temperature-sensitive products, many of which are pharmaceuticals. You described a typical device as containing one battery embedded into a monitoring device and sealed in a solid case. Each production lot of temperature monitoring devices is subjected to a drop test in all directions fiom a height of 1 meter onto a solid concrete floor. A temperature monitoring device may be attached to a pallet or package, placed inside a package, or built into a packaging. You indicated there is some confusion as to whether temperature monitoring devices are acceptable for transportation on aircraft by the HMR. Lithium cells and batteries contained in equipment that meet the requirements of SP 188 are not subject to any other requirements of the HMR by any mode of transportation, including aircraft. A person who offers for transportation small lithium cells or batteries contained in equipment under SP 188 must ensure that the cells or batteries comply with each of the requirements of SP 188. The requirements in SP 188 of the HMR applicable to small lithium cells and batteries contained in equipment are as follows: (1) The lithium content is limited to I gram per cell or 2 grams per battery; (2) the equipment must contain no more than 5 kg (1 1 lbs) of batteries and contain no more than the maximum number of batteries necessary to power the piece of equipment; (3) effective October 1,2009, each cell or battery must be of a type proven to meet the <<>> requirements of each test in the UN Manual of Tests and Criteria; and (4) the batteries and equipment containing the batteries must be packaged in a manner which precludes sparks or the evolution of a dangerous quantity of heat. Under 173.22 of the HMR, it is the shipper's responsibility to properly class a hazardous material. Such determinations are not required to be verified by this Office. However, based on the information included with your letter, it is the opinion of this Office that your product contains a single lithium metal battery containing less than 1.0 gram of lithium and the device is unlikely to generate sparks or a dangerous quantity of heat. You should also note the Federal Aviation Administration may require evidence that this device will not cause interference with the navigation or communication system of the aircraft on which it is to be used. The documents attached are for your future reference regarding how the FAA handles devices1 batteries aboard aircraft. 1 trust this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, UP Edward T. Mazzullo Director, Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration <<>> Page 1 of 1 From: Mazzullo, Ed Sent: Thursday, December 11, 2008 4:08 PM To: Drakeford, Carolyn Cc: Betts, Charles ; Gorsky, Susan ; Kelley, Shane Subject: FW: Request for Assessment: Lithium Batteries in Temperature Monitoring Devices Attachments: 08121 1 Letter to DOT.pdf; CE-Deklaration Libero.pdf; Minamoto IVlaterial safety specifications-MSDS-ER-battery.pdf; Tadiran Battery specification-pdc06engSL-761 .pdf; Team LIBERO technical specs.pdf; Technical Note Tadiran.pdf From: Martin Peter [mailto:martin.peter@elpro.com] Sent: Thursday, December 11, 2008 5:22 AM To: Mazzullo, Ed Cc: Sylvain Riendeau; Kaspar Frick Subject: Request for Assessment: Lithium Batteries in Temperature Monitoring Devices Dear Mr. Mazzullo, This week I have been forwarded a letter (email) from you to Mr. Henry Ames at Sensitech where you assess the compliance of Sensitech's temperature monitoring devices with the relevant regulations. Similar to Sensitech, Elpro is a company developing, producing and marketing temperature monitoring devices globally for the pharmaceutical industry. The current discussion around the interpreation of the regulation by airlines in regards to transporation of pallets containing temperature loggers powered by lithium batteries is causing major discussions amonts the pharmaceutical industry - especially in the USA but increasingly also in Europe and Asia. Attached to this mail you find a letter summarizing our request and position as well as the relevant attachments to support our position. Please no not hesitate to call me in case you have questions or comments. Kind Regards, Martin Peter Martin Peter ELPRO-BUCHS AG Langaeulistrasse 62 9470 Buchs Switzerland Tel: +41 (0) 81 750 03 11 Mob: +41 (0) 79 307 03 65 Fax: +41 (0) 81 750 03 17 martin,eeter@e!~ro,com I htt~./!zw,elelo~.c.~m Libero PDF-Logger: htt~://www.pdf-dataIouqer.com Online-Man itoring: htt~:!!~~.~,elpro!og~.c9m!e!~~o~d.e.m.o <<>> ELPRO-BUCHS AG Langaulistrasse 62 T +41 (0)81 750 03 11 ~ . e l p r o . c o m CH - 9470 B U C ~ S SG F +41 (0)81 750 03 17 Switzerland e swissQelpro.com ~unur, ASSURED ISO 9001 U.S. Department of Transportation Edward T. Mazullo Director, Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration Washington, DC 20590 Request for Assessment of Elpro's Temperature Monitoring Devices in regards to compliance with HMR; 49 CFR Parts 17 1 - 180 and the Special Provisions (SP) 1 88 of 5 172.102(c)(l). Similar to Sensitech, which you recently issued your assessment of their temperature monitoring devices in regards to above mentioned provisions, Elpro is manufacturing and marketing temperature monitoring devices internationally used for Cold Chain Monitoring of pharmaceuticals transported via air-cargo (and other means of transportation): Product Name Libero Ti 1 Libero Ti1 -5 Libero Ti1 -L Libero Til-D Libero Tel-N Libero Tel-P Libero THi1 Manufacturer, type & amount of Lithium per battery Minamoto, Li-SOCI2, 0.789 Minamoto, Li-SOCI2, 0.789 Tardian, Size AA, 0.559 Tardian, Size AA, 0.559 Tardian, Size AA, 0.559 Tardian, Size AA, 0.559 Tardian, Size AA, 0.559 Function of product (for details see attached "Team LIBERO technical specs 3 Temperature monitoring, internal sensor Temperature monitoring, internal sensor Temperature monitoring, internal sensor Temperature monitoring, internal sensor Temperature monitoring, external sensor g Temperature & humidity monitoring, internal sensors Each device contains one battery only. All above mentioned batteries are primary lithium batteries and they comply with the standards SP 188 and UN Manual of Tests and Criteria as: Both battery types used contain >> The Source of Electric Power MINAMOTOB MINAMOTO BATTERY LTD. Flat A-6, SF., Mai Hing Industrial Building, 16-18 Hing Yip Street, Kwun Tong, Kowloon, Hong Kong. Tel: (852) 2793 4790 Fax: (852) 2793 4932 e-mail : info@minamoto.com Material Safety Data Sheet (form according to EEC Directive 9311 121EC) I 1. Identification of the product and supplier ldentification of the product: Lithium, Thionyl Chloride (Li-SOC12) notwechargeable batteries 1 2. Composition and information about the ingredients 1 Active materials Lithium (Li) Carbon black (C) Thionyl chloride (SOCL2) Lithium aluminum tetrachloride (Li AICM) I Weight grams -I 0.78 0.62 5.9 0.77 - Passive materials Base Metal 1 other& Weight grams Steel 8.3 Plastic 0.7 I Glass fiber 0.4 - p~ 1 3. Hazards identification The lithium-thionyl chloride batteries are not hazardous when used according to the recommendations of the manufacturer. But if the design of the circuit doesn' t forecast all the necessary cares to prevent the inversion of polarity in the assembly of the battery or the battery bt packs, there is the risk of dangers due to the explosion of the battery. Define with care the assembling process to assure that accidental short circuit don' t happen. Do not expose the batteries to temperatures above 100°C. - Page 111 - <<>> If the battery lose its integrity and sealing, due to break or damages (mechanical, thermal or electrical), leakage, explosion or fire may follow. In this case there is the risk of release of chemical materials as defined in the paragraph 2 (active materials) of this safety sheet. Here below are shown the nature of special risks and the advices of caution. Nature of special risks R14115 (reacts with water and yields flammable gases) R21 (harmful in contact with skin) R22 (harmful if swallowed) R35 (causes severe burns) R41 (risk of serious damage to the eye) R42143 (may cause sensitation by inhalation and skin contact) Safety advices S2 (keep out of reach from children) S8 (keep away from moisture) S22 (do not breathe dust) S24 (avoid contact with skin) S26 (in case of contact with eyes, rinse immediately with plenty of water and seek medical attention) S36 (wear suitable protective clothing) S37 (wear suitable gloves) S43 (in case of fire use extinguisher type D. DO NOT USE WATER) S45 (in case of incident or indisposition seek medical attention) 1 4. First aid measures Only in case of contact with internal components of the battery: Skin contact: Eye contact: Inhalation: Ingestion: flush with plenty of water flush with plenty of water (eyelids held open) breath fresh air and give oxygen or artificial respiration by specialist people drink much water and consult a doctor I 5. Fire-fighting measures Extinguishing media: extinguishers type D, Lith-X, DO NOT USE WATER in case of battery leakage Special hazards: irritating vapour Special protective equipment: wear protective clothing, use self-contained breathing apparatus with filtered cartridge type ABEK - Page 212 - <<>> 1 6. Accidental release measures In case of break of a battery, all the people must go away from the place where the incident happened and come back only after the dissolution of the irritating gas. Broken batteries or battery packs must be covered with sodium carbonate (Na2C03) or dry sand, place them in approved container and dispose in accordance with local regulation. For the eventual handling use gloves in VitonB. 1 7. Handling and storage 7.1 Handling: - Do not recharge - Do not use different types and brands of batteries or with different state charge - Avoid short circuit - Use desk of work electrically insulated - Avoid to work over wet surface - Use plastic calibre to valuate the dimensions of a Lithium battery or to insulate the metallic surface of the battery - Do not have rings on the fingers; otherwise wear insulating gloves. - Do not cut in the same time both the terminals of a battery: it could be a short circuit trough the shears - Keep the batteries in nonconductive trays (i.e. plastic, wood or carton) - Do not solder directly on the battery - Do not disasserr~ble the batteries, do not throw them in the fire, do not hole, do not overheat or plunge into water 7.2 Storage: - Store the Lithium cells in a cool, dry and ventilated area far from fires and heating sources. - It is recommended the use of a noncombustible structure, keep adequate clearance between walls and batteries. - The maximum temperature suggested for the storage is +30° C - Higher temperatures are allow but cause an increase in the self discharge of the battery and speed up the process of passivation - in any case, never go over 100 "C, as the batteries can break and cause a leakage - Arrange adequate protections to avoid possible hurts to the batteries - Keep the batteries in their original packages till when they are used - Do not expose the batteries directly to the sun light - Do not put an higher number of cartons one on another (respect what indicated) - If in the same place are storage batteries with a total capacity > 50,000 Ah, it is suggested to install an alarm for smoke and gas - Page 313 - <<>> 1 8. Exposure controlslpersonal protection If the battery is integral, storage and handle with care, there is any dangers. It is suggested to handle the batteries in a ventilated place, to don' t smoke, eat or drink during the assembling. 1 9. Physicalaand chemical properties Appearance: The battery ER34615M is a metal cylinders with diameter 34,2mm and height 61,5 mm, fitted with an external plastic sleeve. 10. Stability and reactivity 10.1 Conditions to avoid: Do not expose at temperature higher than 100" C. Avoid short circuit, crush, exposition to heat sources. Do not disassemble the batteries or the battery packs, do not throw them in the fire, do not perforate them, do not overheat or wet them. 10.2 Material to avoid: Water, oxidizing agents, alkalis. I 1 I. Toxological information I The rupture of a lithium-thionyl chloride batteries can developed the following substances: - Hydrogen (H2), lithium Oxide (Li20) and lithium Hydroxide (LiOH) in case of reaction of lithium metal with water - Chlorine (Clz), sulfur dioxide (S02) and disulfur dichloride (S2C12) if the thionyl chloride go above 140,5"C - Hydrochloric acid (HCI) and sulfur dioxide (S02) in case of reaction of thionyl chloride with water - Hydrochloric acid (HCI), lithium oxide (LizO), lithium hydroxide (LiOH) and aluminium hydroxide (AI(OH)3) in case of reaction of lithium thetrachloroaluminate with water. 1 12. Ecological information When properly used or disposed, the lithium-thionyl chloride batteries do not present environmental hazard. I 13. Disposal consideration For the disposal apply to specialized organisation. - Page 414 - <<>> 1 14. Transport information Restriction for the transport: class 9 in accordance to the United Nation regulation. International convention Road transport: not hazardous in accordance to ADR Rail transport: not hazardous in accordance to RID Sea transport: not hazardous in accordance to INlDG Air transport: not hazardous in accordance to ICAO Note: the batteries which contain few than 0,5g of metal lithium are not restricted for transport. 1 15. Regulation information The transport of lithium batteries is regulated by ONU as described in the " Recommendations of the Transport of Dangerous Goods ref.STISG1AC. 1011 -Ed.-1 I - 2000" . Depending on their lithium metal content (quantity higher than 0,5g), the batteries may or may not be assigned to the transport restrictions, following the rules defined in the ONU document " Recommendations of the Transport of Dangerous Goods". 1 16. Other information The lithium-thionyl chloride batteries or battery packs must be handle by specialize people. They must be kept out of reach from children. They must be used following the Technical Specifications, without exceed the values defined. Do not assemble by one self a serial of batteries, but request the finished battery to the supplier, who will provide for install protection components (diodes, etc..) The information contained in this sheet are based on the present knowledge and the conditions of use. For every use not in conformity to the safety sheet or for the use in combination with any other material or in any other process the user is the responsible. The responsible of the products - Page 515 - <<>> Tadiran Batteries GmbH Industriestr. 22 D-63654 Budingen Tel. +49(0)6042/954-0 www.tadiranbatteries.de TADIRAN BATTEXKKES Keyword: Lithium Xtra Model: SL-761 WARNING: Fire, explosion, and severe burn hazard. Do not Performance Data Size %AA recharge, disassemble, (Typical values for batteries stored at 25°C for one year) heat incinerate, or expose Svstem LiISOCI. contents to water. Nbmina~ voltage Nominal capacity UL recognition under file MH 12827 Nominal current Max. continuous discharge current 30 mA Pulse current capability 90 mA See also our website Anode surface area 9 cm2 under ProductsISafety Lithium content 0.5 g Weight 12 9 Volume 5.7 cm3 Temperature range -55...+85 "C Typical Discharge Curves at +25"C 4.0 L I 0.0 t-L I ''''111 ' ' """l ' '"1"11 ' 1"'11'1 ' ' 1"1111 I ' "LUJ 0.1 i 10 102 l o 3 l o 4 105 Time hours Available Capacity 1.6 r I I I I 1 0.15 thick Current ImA Operating Voltage -50 -35 -20 -5 10 25 40 55 70 85 100 Temperature /"C Pulse Discharge Characteristics at +25"C 0.2 thick 0.2 thick 4.0 3.5 Available Terminations Catalogue No. Any values given here are for information purposes SL-7611s Standard 11 1 07611 00 only. They also depend on SL-761n Tags 1 1 1 0761 2 00 actual conditions of use SL-761lP Pins 11 1 07613 00 and are not warranties of SL-761 IPR Pins Radial 11 1 07616 00 future periormance. SL-761lPT Polarized Tags 11 10761800 Subject to change. 0.0 0 200 400 600 800 1 0 0 0 ~ Time /hours f <<>> Team LIBERO - Technical Specifications Picture TYPe Part number Application area Record options Record mode Probe type Measurement range Accuracy - - Mobile Temperature 1 ~ e m ~ e r a t u F & Humidity Data ~ 0 ~ ~ ; s 4510 1 4511 45 12 45 13 4514 4515 ) 4516 Supply chain tem~erature monitorina 1 Standard 1 Tem~erature I Temperature ( Liquid Nitrogen I Supply chain . . . > temperature mon'itoring for monitoring for and cooling cabi- temperature & monitoring, dry ice shipments dry ice shipments DT1 successor monitoring Multiple use Startlstop mode or Loop mode Internal NTC probe Single use StaNstop mode only Multiple use Start/stop mode or Loop mode Single use Start/stop mode only Multiple use Startlstop mode or Loop mode LIBERO NTC probe with connector, cable length 50 cm 3094-LL005: 90.- o r 3 m 3094-LLO3: 130.- LIBERO PTlOO probe with connector, cable length 50 cm 31 63-LL005: 180.- Combined internal probe TlrH - -35..70 "C 1 -35..70 "C -35..70 "C -80..70 "C -80..85 OC -200..200 O C -35..70 "C 0..100 %rH -1Oo..25"C +I-0.2' 25"..7OoC +I-0.5" 25"..2OO0C +/-1.0" 25"..70°C +/-I .OD 25"..70°C +I-0.5" -loo..-200°C +I-1.0" OD..-35°C +/-I .O0 -loo..-35°C +/-0.5" -1 O0..-35°C +/-0.5" t0%..90% rH +I- 2% -3S0..-80°C +/-I .go 0%..10%% rH +/- 3% 90%..100% rH +/- 346 Resolution 1 1/10° .. . - Memory capacity 16'000 measuring data points Programmable measurement interval and display renewal minute or more, programmable 1 8'000 each - -- Marketing I AR Team Libero - Technical Specifications - Prices and specifications are subject to change without notice! October 15, 2008 <<>> P.O. BOX 1 TADxRAN & KIRYAT EKRON BATTERIE S D ~ ~ 7 ~ 7 ~ ~ $ 4 4 4 5 0 3 FAX: (972-8) 9413079 See us on the web: www.tadiranbat.com Guidelines for shipping Lithium Batteries 1. Scope This document is about the new UN regulations for transportation of lithium cells and batteries as detailed in the Model Regulations on the Transport of Dangerous Goods Ref STISGIAC. 10-1 Revisi0.n 12-2001 (UN 3090). The regulations also cover the IATA, ICAO, and ARD requirements. Transportation in the USA is subject to CFR49, which does not yet include the new LJN regulations. The change to the new UN regulations in the USA is expected on the third quarter of 2003. Therefore, shippers in the USA can stay now with the current transportation regulations, except when transporting out of the USA. In this case, shippers have to comply with the new UN regulations. The following guidelines impart an immediate, basic working knowledge for shipping Tad.iran Lithium Batteries and Cells safely and legally. This information should be viewed only as a guide to existing regulations and not a regulation in and of itself. 12. Shipping Methods The shipping method is determined by the amount of lithium in a cell or a battery. The shipping regulations define two groups. - Non-Restricted - Class 9 2.1 Non-Restricted fi 3090 defined as non-restricted, all cells that have less than one gram of lithium and all batteries that have less then two grams of lithium. Provided that each cell and each battery passed successfully the tests per UN specification; (Recommendation on the Transport of Dangerous Goods, Manual of Test and Criteria, paragraph 38.3). A list of Tadiran products with the amount of lithium in each product is presented in Appendix # 1. Shipping of non-restricted articles requires the cells and the batteries to be separated in such a way to prevent short circuit, and they must be packed in strong packaging, except when installed in equipment. Except when installed in equipment, or for packages that contain more than 24 lithium cells or 12 lithium batteries they should comply with the following addition requirements <<>> P.O. BOX 1 TADxmAN $ KIRYAT EKRON BATTERIES D 7 E ~ ~ ~ 7 ~ ~ ~ ) 0 ~ 4 4 4 5 0 3 FAX: (972-8) 941 3079 1 See us on the web: www.tadiranbat.com 2.1.1 Each package must be marked indicating that it contains lithium batteries and that special procedures should be followed in the event that the package is damaged. See Appendix # 2. 2.1.2 Each shipment must be accompanied with a document indicating that the packages contain lithium batteries and that special procedures should be followed in the event a package is damaged. See Appendix # 3 2.1.3 Each package is capable of withstanding a 1.2 meter drop test in any orientation without damage to cells or batteries contained therein, without shifting of the contents so as to allow battery to battery (cell to cell) contact and without release of contents. 2.1.6 Except in the case of lithium batteries packed in equipment, packages may not exceed 30Kg gross mass in all transportation modes air, sea and ground. 1 2.2 class 9 I Class 9 (Restricted), are all cells that have more than one gram of lithium and all batteries that have more then two grams of lithium, provided that each cell and each battery passed successfully the tests per LTN specification: (Recommendation on the Transport of Dangerous Goods, Manual of Test and Criteria, paragraph 38.3). A list of Tadiran products with the amount of lithium in each product is presented in Appendix # 1. Following are the requirements for shipping of Class 9 articles. 2.2.1 The maximum gross weight per a single package that carry Class 9 (Restricted) articles is detailed below. Modes of Transportation Passenger Airplane Cargo Airplane Sea Ground Gross Weight in Kg 5 35 Over 35 Over 35 2.2.2 The completion of RESTRICTED ARTICALES CERTIFICATION from Declaration for Dangerous Goods Form) in according with detailed instruction manual. This document must be carefully typewritten with no mistake, or corrections, and can only be signed by legally certified person. 2.2.3 Enclosing an International Airway Bill. 2.2.4 Enclosing three copies of commercial invoice. <<>> P.O. BOX 1 TAD1 RAN $ KIRYAT EKRON ISRAEL 70500 B*TTE-ES I, TEL: (972-8,9444503 FAX: (972-8) 9413079 See us on the web: www.tadiranbat.com 2.2.5 Proper packaging: The outer packaging must be Group I1 package such as fiberboard box (specified number is 4G) with proper UN specs marks on the carton (sturdy shipping cartons meeting UN Performance specification testing). 2.2.6 Labels: - Class 9 label - "Cargo Aircraft Only" label when shipped by cargo aircraft. - Label stating company name, address - The following statement, must appear on the carton: Lithium Batteries UN NBR 3090 CLASS 9 Pkg. Inst. 903 I1 S.T.C Gross weight in ------------ Kg PACK NO .-------- OF ---------- F ote: For shipment to USAICANADA a 24hour phone number available to call in event fan emergency, must be included in the shipping documents. 4. Over pack Over pack: An enclosure used to provide protection or convenience in handling o package or to consolidate two or more packages. The package being over packed must e eligible to be transported by itself, and properly prepared for shipment with proper arking and labeling. The marking and labeling on each of the packages being over acked must be reproduced on the outside of the over pack unless visible from outside of Package: The end result of the packaging process, which includes all the azardous content, and all of the packaging properly closed and prepared for proper arking and labeling. 5. Training SA employees involved in packaging or shipment of Class 9 batteries must complete a FR 49 certified hazardous material shipping training course. The certification should be enewed every three years. In face of the new revision, it is strongly recommended that he employees also complete the IATA training course i <<>> P.O. BOX 1 TADxRAN $ K1RY.T EKRON ISRAEL 70500 BATTEICIE TEL: (972-8) 9444503 FAX: (972-8) 9413079 See us on the web: www.tadiranbat.com 6. Violations of shipping regulation rules kViolation of the US DOT HMR (Hazardous Material Regulation) is subject to a me of up to$27,500. Multiple fines may be imposed for a single shipment for each type <<>> P.O. BOX 1 TADxmAN $ KIRYAT EKRON ISRAEL 70500 TEL: (972-619444503 FAX: (972-8) 9413079 See us on the web: www.tadiranbat.com u I TECHNICAL NOTICE i i Appendix # 1, Quantity of lithium metal in Tadiran cells and Batteries <<>> Appendix# 2, label for package with non-restricted cells or batteries a -,=m CAUTION ! Lithium Batteries inside Flammable if damaged Handle with care if package is damaged, batteries must be quarantined, inspected and repacked. For emergency information, call: 1-800424-9300 <<>> P.O. BOX 1 TADIRAN & KIRYAT EKRON BATTERIES D ~E~7~7~0,"~g"444503 FAX: (972-8) 9413079 See us on the web: www.tadiranbat.com Appendix # 3, example of shipping document for non-hazardous cargo Shippers Certification for Non-Hazardous Cargo AWB No. A l r p o r t o f Dep. I I I This 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 described 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 Dangerous Goods Regulations ( D G ~ ) . Alphabetical Llst a? Dangerous Goods, no'r d o they correspond t o a n y of the hazard classes appearing in the DCR, Sectian 3, classificatlon o f Dangerous Goods and t h a t t h e y are known t o be n o t danqerous, 8.e. not restricted. Furthermore the Shipper confirms t h a t the goods a r e in proper condition for transportation o n passenger c a r r y i n g aircraft. Marks a n d Number of Packages Proper Description o f Goods (Tradel'Narnes not Permitted) Specify each article separately Net quantity p e r package . . ..-.. . Name a n d Address o f Shipper Signature 'To-be completed in duplicate:'' 7Distribution: One copy t o accompany the A W B " " to b e filed a t airport o f departure [ w i t h AWB-copy) I <<>> P.O. BOX 1 TADI[RAN $ KIRYAT EKRON BATTElRIE S D ~E~7~7~0~~~444503 ~ -- I - - - * - ~ - - FAX: (972-8) 941 3079 See us on the web: www.tadiranbat.com Appendix # 4, shipper declaration for Dangerous Goods, (Class 9) <<>> P.O. BOX 1 TAD1 RAN $ KIRYAT EKRON ISRAEL 70500 BATTE-E * TEL: ,9724,9444503 FAX: i972-8j 9413079 See us on the web: www.tadiranbat.com r Appendix # 5 label for package with Class 9 (restricted) cells or batteries Note: The above label will be used when goods have to be shipped with Cargo Airplanes only. Lithium Batteries UN NBR 3090 CLASS 9 Pkg. Inst. 903 I1 S.T.C Gross weight in ------------ Kg <<>> LTN 11111 10 of 10 <<>> Advisory Circular Subject: Use of Portable Electronic Devices Aboard Aircraft Date: 8/25/06 AC No: 91-21.1B Initiated by: AFS-350 1. PURPOSE. This advisory circular (AC) provides aircraft operators with information and guidance for assistance in compliance to Title 14 of the Code of Federal Regulations (14 CFR) part 91, section 91.21. Section 91.21 was established because of the potential for portable electronic devices (PED) to interfere with aircraft communications and navigation equipment. It prohibits the operation of PEDs aboard U.S.-registered civil aircraft while operating under instrument flight rules (IFR). This rule permits use of specified PEDs and other devices that the operator of the aircraft has determined will not interfere with the safe operation of that aircraft. The recommendations contained herein are one means, but not the only means, of complying with section 91.21 requirements, pertaining to the operation of PEDs. 2. CANCELLATION. AC 91-21.1A, Use of Portable Electronic Devices Aboard Aircraft, dated October 2, 2000, is canceled. 3. RELATED 14 CFR SECTIONS. Section 91.21, 121.306, 125.204, and 135.144. 4. BACKGROUND. a. Section 91.21 (formerly section 91.19) was initially established in May 1961 to prohibit the operation of high-frequency omnidirectional range was being used for navigation purposes. The Federal Aviation Administration (FAA) subsequently determined that other PEDs could be potentially hazardous to aircraft communication and navigation equipment, if operated aboard aircraft. Amendment 91-35 amended the scope of former section 91.19 to prohibit the use of additional PEDs aboard certain U.S. civil aircraft. Section 91.21, as adopted, was drafted to require the air carrier or commercial operator to determine whether a particular PED will cause interference when operated aboard its aircraft. b. RTCA Special Committee 156 accomplished a study of the potential for interference from PEDs and released Document No. RTCA/DO-199, volumes 1 and 2, entitled “Potential Interference to Aircraft Electronic Equipment from Devices Carried Aboard.” RTCA Special Committee 177 did a further study of these devices and released Document No. RTCA/DO-233, entitled “Portable Electronic Devices Carried on Board Aircraft.” The finding and conclusions from these two studies helped the FAA establish the current policy which allows the use of non-transmitting PEDS during non-critical phases of flight. In March 2003, the FAA requested that RTCA form a special committee to evaluate and develop guidance related to assess the impact and risks related to the use of <<>> AC 91-21.1B 8/25/06 intentionally radiating PEDs (transmitting PEDs, or T-PEDs) that passengers may bring onto civil aircraft. These include mobile telephones, computers with wireless network capabilities, and other wireless-enabled devices such as Personal Digital Assistants (PDA). On October 19, 2004, RTCA released Document No. DO-294, prepared by Special Committee 202, titled “Guidance on Allowing Transmitting Portable Electronic Devices (T-PEDS) on Aircraft” (to obtain RTCA documents see paragraph 8b). c. Other activities in this area were done by the Consumer Electronics Association when in October, 2004; they issued a standard practice to help manage the use of wireless devices on board aircraft that would greatly enhance the flightcrew and the flying public’s ability to comply with airline policies for portable electronic devices. 5. DISCUSSION. a. The related 14 CFR sections in paragraph 3 allow for the operation of PEDs that the operator of the aircraft has determined will not interfere with the navigation or communication system of that aircraft. In addition to the originally addressed non-transmitting PEDs, this revised AC also recognizes and provides guidance on the potential use of T-PEDS. It should be noted that the responsibility for permitting passenger use of a particular PED technology lies solely with the operator. RTCA/DO-233, current edition, provides government agencies and aircraft operators with recommendations for acceptable use of certain non-transmitting PEDs onboard aircraft. The current edition of RTCA/DO-294 identifies a process for airlines to make a determination of acceptable use of T-PEDs. The determination of an interfering effect caused by a particular device on the navigation and communication system of the aircraft on which it is to be used or operated must, in case of an aircraft operated by the holder of an air carrier certificate or other operating certificate, be made by that operator (i.e., certificate holder). In all other cases, a determination must be made by the operator and/or by the pilot-in-command (PIC). In some cases, the determination may be based on operational tests conducted by the operator without the need for sophisticated testing equipment. b. When safely at cruise altitude, the pilot could allow the devices to be operated. If interference is experienced, the types of devices causing interference could be isolated, along with the applicable conditions recorded. The device responsible for the interference should then be turned off. If all operators collect this type of data with specific information, a large enough database could be generated to identify specific devices causing interference. The operator may want to obtain the services of a person or facility capable of determining non-interference to the aircraft’s navigation, communication, or other electronic system. Personnel specifically designated by the air carrier or commercial operator for this purpose may make this determination using the process described in RTCA/DO-294. For other aircraft, the language of the rule expressly permits the determination to be made by the Pilot in Command or operators of the aircraft. Thus, in the case of rental aircraft, the renter-pilot, lessee, or owner-operator could make the determination. 6. RECOMMENDED PROCEDURES FOR THE OPERATION OF PEDs ABOARD AIRCRAFT. If an operator allows the use of PEDs aboard its aircraft, procedures should be established and spelled out clearly to control their use during passenger-carrying operations. The procedures, when used in conjunction with an operator’s program, should provide the following: a. Methods to inform passengers of permissible times, conditions, and limitations when various PEDs may be used. This may be accomplished through the departure briefing, passenger Page 2 Par 4 <<>> 8/25/06 AC 91-21.1B information cards, captain’s announcement, and other methods deemed appropriate by the operator. For air carrier operations conducted under 14 CFR part 121 or part 135, the limitations, as a minimum, should state that use of all such devices (except certain inaccessible medical electronic devices, for example, heart pacemakers) are prohibited during any phase of operation when their use could interfere with the communication or navigation equipment on board the aircraft or the ability of the flightcrew to give necessary instructions in the event of an emergency. b. Procedures to terminate the operation of PEDs suspected of causing interference with aircraft systems. c. Procedures for reporting instances of suspected or confirmed interferences by a PED to a local FAA Flight Standards District Office or the FSDO that has certificate management responsibility for the air carrier. d. Cockpit to cabin coordination and cockpit flightcrew monitoring procedures. e. Procedures for determining non-interference acceptability of those PEDs to be operated aboard its aircraft. Acceptable PEDs should be clearly spelled out in oral departure briefings and by written material provided to each passenger to avoid passenger confusion. The operator of the aircraft must make the determination of the effects of a particular PED on the navigation and communication systems of the aircraft on which it is to be operated. The operation of a PED is prohibited, unless the device is specifically listed in section 91.21(b)(1) through (4). However, even if the device is an exception from the general prohibition on the use of PEDs, an operator may prohibit use of that PED. The use of all other PEDs is prohibited by regulation, unless pursuant to section 91.21(b)(5). The operator is responsible for making the final determination that the operation of that device will not interfere with the communication or navigation system of the aircraft on which it is to be operated. f. Prohibiting the operation of any PEDs during the takeoff and landing phases of flight. It must be recognized that the potential for personal injury to passengers is a paramount consideration, as well as is the possibility of missing significant safety announcements during important phases of flight. This prohibition is in addition to lessening the possible interference that may arise during sterile cockpit operations (below 10,000 feet). 7. CELLULAR & ONBOARD TELEPHONE SYSTEMS. a. T-PEDs have considerations in addition to those listed in paragraph 6. These include cellular telephones, citizens band radios, remote control devices, computers with wireless network capabilities, and other wireless-enabled devices such as PDAs, etc. The Federal Communications Commission (FCC) currently prohibits the use of cell phones while airborne. Its primary concern is that a cell phone, used while airborne, would have a much greater transmitting range than a land mobile unit. Their use could result in unwanted interference to transmissions at other cell locations since the system uses the same frequency several times within a market or given operating area. Since a cell phone is capable of operating on various cellular frequencies, unwanted interference may also affect cellular systems in adjacent markets or operating areas. Par 6 Page 3 <<>> AC 91-21.1B 8/25/06 b. The FAA supports this airborne restriction for other reasons of potential interference to aircraft systems and equipment. Currently, the FAA does not prohibit the use of certain cell phones in aircraft while on the ground. An example might be their use at the gate or during an extended wait on the ground while awaiting a gate, when specifically authorized by the operator. A cell phone will not be authorized for use while the aircraft is being taxied for departure after leaving the gate. The unit will be turned off and properly stowed to prepare the aircraft for takeoff as per the operator’s procedures. Whatever procedures an operator elects to adopt should be clearly spelled out in oral briefings prior to departure or by written material provided to each passenger. c. Onboard telephone systems that are type accepted by the FCC as air-to-ground equipment, which have been permanently installed in t - **truncated:** true - **body characters:** 57291