# Texas Instruments Incorporation — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 15-0027
- **title:** Texas Instruments Incorporation — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2015-11-04
- **effective on:** Not available
- **summary:** 15-0027 response to Texas Instruments Incorporation concerning 173.185.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0027.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0027.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0027
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150027.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
1200 New Jersey Avenue SE
of Transportation
Washington. DC
20590
Pipeline and Hazardous
Administration
Materials Safety
NOV 0 4 2015
Mr. Louis Le
Product Stewardship Manager
Education Technology
Texas Instruments Incorporated
12500 TI Boulevard
Dallas, TX 75243
Reference No. 15-0027
Dear Mr. Le:
This is in response to your e-mails and the supplemental information you provided
requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-
180) applicable to properly shipping calculators that contain lithium-ion batteries. You state
some of your company's calculators that contain these batteries are routinely frustrated in
transit. Specifically, you ask if your company's products meet the conditions of
§ 173.185(c) of the HMR and Special Provision 188 of the International Maritime
Dangerous Goods (IMDG) Code.
You provided the material safety data sheet (MSDS) of the lithium-ion batteries installed in
the calculators. It describes the battery as a 3.7 Volt, 4.44 Watt hour (Wh), lithium ion
battery Model Nos. P11P35-09-N01 and P11P35-11-N01, manufactured by Samsung SDI
Company, Ltd. The MSDS indicates that the batteries are of a type proven to meet the
requirements of each test in the United Nations Manual of Tests and Criteria, Part III sub-
section 38.3. You further state the calculators containing installed batteries are packed in
blister packs and placed in a strong outer packaging.
The information you provided indicates that your shipments of lithium ion batteries
contained in equipment meet the cell/battery testing, size, and packaging requirements of
§ 173.185(c) and Special Provision 188 of the IMDG Code. Hazard communication
requirements in § 173.185 and IMDG Code Special Provision 188 apply to packages that
contain more than four lithium cells or two lithium batteries contained in equipment.
I hope this satisfies your request.
Sincerely,
TAlen Fast
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

<<<PAGE 2>>>

Edmonsen
§173.185()
Batteries
Dodd, Alice (PHMSA)
15 - 0027
From:
Ciccarone, Michael CTR (PHMSA)
Sent:
To:
Monday, February 02, 2015 4:07 PM
Hazmat Interps
Subject:
transportation of product containing Lithium battery
FW: Letter of Interpretation Requested for 49 CFR 173.185 (c) exception for
Importance:
High
Shante/Alice,
Please submit this for formal letter of interpretation. Mr Le spoke to Shelby in the HMIC.
Thanks,
Mike
From: Le, Louis [mailto:louis.le@ti.com]
To: PHMSA HM InfoCenter
Sent: Monday, February 02, 2015 3:42 PM
Subject: Letter of Interpretation Requested for 49 CFR 173.185(c) exception for transportation of product containing
Lithium battery
Importance: High
I have products that contains Lithium lon battery or Lithium Metal battery. Currently, there are delayed in country due
to authorities and/or carriers stating that due to the product being categorized as an calculator that contains an lithium
battery is an Dangerous Goods. HS codes that is used for my product is 8470.10.0000
UN3481 - Lithium ion contained in equipment
Battery Capacity / Lithium Content per battery
<= 20Wh/ Cell and not more than 4 cells or
<= 100Wh / Battery and not more than 2 batteries
Texas Instruments Incorporated Lithium lon batteries are 4.44Wh and contains 1 Cell or 1 Battery
UN 38.3 T1-T8 Rev.3 Am1 tested and passed.
UN3091 - Lithium metal contained in equipment
Battery Capacity / Lithium Content per battery
<= 1 gram of Lithium / Cell and not more than 4 cells or
<= 2 grams of Lithium / Battery and not more than 2 batteries
Texas Instruments Incorporated Lithium Metal batteries CR2025 contains 0.042 grams of Lithium and CR2032 contains
0.06 grams of Lithium.
UN 38.3 T1-T8 Rev.3 Am1 tested and passed.
Please confirm that Texas Instruments Incorporated products meets the DOT 49 CFR 173.185(c) and IMDG Special
provision 188 therefore should be deemed non-Dangerous Goods or General Cargo for air, rail, road, and vessel
shipment and exempted from requirements in 49 CFR Part 172, Subparts C, D, E, F, G, and H and UN performance
packaging requirements prescribed in 49 CFR 173.185(b)(3)(ii) an d(b)(4).
Regards,
1

<<<PAGE 3>>>

Louis Le
Product Stewardship Manager
Texas Instruments Incorporated
Education Technology
12500 TI Blvd
Dallas, TX 75243
214-567-4653
louis.le@ti.com
"Things do not happen. Things are made to happen" - John F. Kennedy
This e-mail and any attachments may contain confidential and privileged information. If you are not the intended
recipient, please notify the sender immediately by return e-mail, delete this e-mail and destroy any copies. Any
illegal. Unless otherwise stated, opinions expressed in this e-mail are those of the author and are not endorsed by the
dissemination or use of this information by a person other than the intended recipient is unauthorized and may be
author's employer.
2
- **truncated:** false
- **body characters:** 4906