{"operation":"document","citation":"11-0124","title":"SiGNa Chemistry — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-08-22","effective_on":null,"summary":"11-0124 response to SiGNa Chemistry concerning 175.10.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0124.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0124.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0124","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110124.pdf","body":"<<<PAGE 1>>>\n\nu.s. Department 1200 New Jersey Avenue SE\nof Transportation Washington, DC 20590\nPipeline and Hazardous\nMaterials Safety\nAdministration\nAUG 2 2 2011\nMr. Michael Lefenfeld\nPresident & Chief Executive Officer\nSiGNa Chemistry\n445 Park Avenue, Suite 10 10\nNew York, NY 10022\nRef. No. 11-0124\nDear Mr. Lefenfeld:\nThis responds to your May 18, 2011 letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) regarding the transportation in carry-on luggage of\nfuel cell cartridges by aircraft. Specifically, you request confirmation that a portable electronic\ndevice powered by a fuel cell cartridge containing sodium silicide (Division 4.3) may be\ntransported under the provisions of § 175.10(a)(l9). You indicate that the fuel cell cartridge\nconforms to the specifications of IEC/P AD 62282-6-1, which is incorporated by reference in\nthe HMR and provides that \"the manufacturer may consider fuels, materials, designs or\nconstructions not specifically dealt with in this document. These alternatives shall be evaluated\nas to their ability to yield levels of safety equivalent to those prescribed by this standard.\"\nYes. Based on the information you provide in your letter, the fuel cell powered device is\neligible for the exception in § 175. 1 0(a)(19). The fuel cell powered device must comply with\nall requirements in § 175.1 0(a)(l9), including the manufacturer marking \"APPROVED FOR\nCARRIAGE IN AIRCRAFT CABIN ONLY.\"\nI hope this answers your inquiry. If you need additional assistance, please contact this office at\n(202) 366-8553.\nSincerely,\n~5~\nBen Supko\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nW;V1Hr\n~ 115.10 (a) (1'1)~~\n11 • \" .L Ii'~. WiDDer ofthe\nH'\"I YCI\"'a-rr· fl 200S Presi,dmdal\nSiGNa \" I J Gteen Cbemistry\nCHEMISTRY I I- &I 2-, ~~ Challenge Award\nWednesday, May 18, 2011\nMr. Charles Betts\nDirector, Office of Hazardous Materials Standards (PHH-I0)\nU.S. Department of Transportation, PHMSA\n1200 New Jersey Ave., SE.~ ,\nWashington, DC 20590\nDear Mr. Betts:\nI am writing regarding interpretation of 49 CFR § 175.10 (a) (19), as it pertains to crew and passenger\ncarriage of Fuel Cell Cartridges containing water reactive substances (UN 3476) on passenger aircraft.\nThis provision authorizes passengers and crew to carry fuel cell cartridges onboard passenger aircraft\nwhen, among other requirements, they conform to a publicly available specification from the\nInternational Electrotechnical Commission, IEC/PAS 62282-6-1. It is my understanding that you or Mr.\nPfund received copies of the relevant IEC documents through your participation at the recent Atlantic\nCity ICAO Dangerous Goods Panel Working Group meeting. If this is not the case, I would be happy to\nprovide them to you.\nIEC/PAS 62282-6-1, in Annex E ofthe specification, provides for fuel cell cartridges based on\nborohydride compound fuel, which typically is a division 4.3, water reactive material. This specification\nfurther states (sub-clause 1.2) that, liThe manufacturer may consider fuels, materials, designs or\nconstructions not specifically dealt with in this document. These alternatives shall be evaluated as to\ntheir ability to yield levels of safety equivalent to those prescribed by this standard.\"\nSiGNa Chemistry is engaged in the development of a fuel cell cartridge that uses a different Division 4.3\nfuel, sodium silicide, with chemical reactivity comparable to that of borohydride compound fuel (see\npicture on p. 2). Because we evaluate these cartridges in a way that demonstrates a level of safety\nequivalent to that prescribed bit IEC/PAS 62282-6-1 (see test summary, p. 2), and since these fuel\ncartridges are in compliance with all other requirements of the HMR, it is our position that these fuel\ncell cartridges are authorized for carriage by passenger and crew on passenger aircraft under § 175.10\n(a) (19). Do you see any issues with this position?\nThank you for your attention in this matter.\nSincerely,\nMichael Lefenfeld - President & Chief Executive Officer, SiGNa Chemistry\n445 Park Avenue, Suite 1010\nNew York, NY 10022\nPhone: +1-212-933-4101\nCc: Duane Pfund, PHH-20\nPage 10f2 Lefenfeld to Betts Wednesday, May 18, 2011\n\n<<<PAGE 3>>>\n\nExample of FC system using SiGNa Cartridges:\nTest Summary\nTo ensure equivalence as provided by lEe 62282-6-1, sub-clause 1.2,\n• SiGNa fuel cell cartridges are tested using the published international standard lEe 62282-6-100\n- this is the final international standard that followed lEe/PAS 62282-6-1}.\n• Testing is also in accordance with the publicly available specification lEe/PAS 62282-6-150,\nwhich provides detailed guidance on safety testing tailored to water reactive materials and that\nestablishes levels of safety equivalent to those prescribed by lEe/PAS 62282-6-1.\nThe validity of using lEe/PAS 62282-6-150 and lEe 62282-6-100 to establish an equivalent level of safety\nto lEe/PAS 62282-6-1 is supported by the in-progress work of an lEe working group of technical experts\nto combine all of these standards and specifications into a second edition of lEe 62282-6-100.\nPage 2of2 Lefenfeld to Betts Wednesday, May 18, 2011","truncated":false,"body_characters":5171}