Morpho Detection, LLC. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Washington, D.C. 20590 Administration MAR 0 3 2016 Aric Tillberg Morpho Detection, LLC 23 Frontage Rd Andover, MA 01810 Ref. No. 15-0202 Dear Mr. Tillberg: This responds to your September 30, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to exceptions for passengers, crewmembers and air operators. Specifically, you ask whether you may carry aboard an aircraft a lithium ion battery pack designed to power a portable handheld instrument used for demonstrations and promotional shows. You state that the battery pack has a capacity of 32 Wh and has been tested to meet the UN Manual of Tests and Criteria, Part III, Sub-section 38.3. Yes. In accordance with § 175.10(a)(18), the HMR authorizes the carriage of portable electronic devices containing lithium cells or batteries, or spare lithium cells or batteries for these devices, when carried by passengers or crew members for personal use. Note that each spare battery must be individually protected to prevent damage and short circuit, and may only be carried in carry-on baggage. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Dane A Tal Duane Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Ciccarone § /75.10 Dodd, Alice (PHMSA) Aircraft 15-0202 Sent: From: Geller, Shelby CTR (PHMSA) To: Tuesday, October 13, 2015 11:19 AM Subject: Hazmat Interps Attachments: FW: Interpretation Request 49 CFR 175 10(a)(18) Interpretation Request 49 CFR 175.10(a)(18) pdf Dear Shante and Alice, I just wanted to follow up on this request as I did not see it in the database. Thanks, Shelby From: Geller, Shelby CTR (PHMSA) Sent: Thursday, October 01, 2015 3:40 PM To: Hazmat Interps Subject: FW: Interpretation Request 49 CFR 175 10(a)(18) Dear Shante and Alice, Forwarded is a request for a formal letter of interpretation. Thanks, Shelby From: Aric Tillberg [mailto:atillber@morphodetection.com] Sent: Wednesday, September 30, 2015 4:33 PM To: PHMSA HM InfoCenter Subject: Interpretation Request 49 CFR 175 10(a)(18) Dear PHMSA Office of Hazardous Materials Standards Division, interpretation? Attached is a request to confirm our interpretation of 49 CFR 175 10(a)(18). Could you please confirm our Best Regards, Aric Tillberg Assistant Radiation Safety Officer Andover/Safety Specialist T M +1 978 495 6592 +1 978 933 4313 F Morpho Detection. LLC +1 866 249 9105 23 Frontage Rd. www.morphodetection.com Andover, MA 01810 SAFRAN Morpho 1#

Page 3SAFRAN Morpho Aric Tillberg Assistant Radiation Safety Officer-Andover Safety Specialist T +1 (978) 495-6592 F +1 (866) 249-9105 23 Frontage Rd.; Andover, MA 01810 USA U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 September 30, 2015 Re: 49 CFR 175.10(a)(18) This letter asks for your clarification of the intent of 49 CFR 175.10(a)(18) with respect to the transport of spare lithium ion batteries in carry-on baggage aboard passenger aircraft. Morpho Detection LLC manufactures the SourcelD Li-Ion Battery Pack to power its SourceD portable hand held instrument. These battery packs have a capacity of 32Wh and have been tested to meet the UN Manual of Tests and Criteria, Part III, Sub-section 38.3. We desire to transport spare SourceiD Li-ion Battery Pack on passenger aircraft in small quantities sufficient for demonstrations and promotional shows and within the constraints of 49 CFR 175.10(a)(18). Batteries transported in this manner are not intended for further sale or distribution. We request your confirmation that spare SourcelD Li-lon Battery Pack may be transported in carry-on baggage on passenger aircraft for the purpose of demonstrations and promotional shows. Please contact me at atillber@morphodetection.com or (978) 495-6592 if have any question regarding this matter. Best Regards, Aric Tillberg Morpho Detection, LLC 23 Frontage Rd Andover, MA 01810 USA www.morphodetection.com T + 1 (978) 933-4300 F + 1 (866) 249 9105#