Mr. Joseph Tsiyoni — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration MAY 1 2 2016 Mr. Joseph Tsiyoni 1415 N. Rose Street Tempe, AZ 85281 Ref. No. 16-0006 Dear Mr. Tsiyoni: This is a response to your December 17, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to a lithium ion battery-powered wheelchair or other mobility aid carried by aircraft passengers or crewmembers. Specifically, you ask for clarification on the rules about the size and capacity of the motor and battery allowed on a wheelchair or other battery-powered mobility aid (e.g., a scooter). Your questions are paraphrased and answered as follows: Q1. Is there a limit to the size or capacity for the motor of a wheelchair or other battery- powered mobility aid? Al. No. Unless the motor has a hazardous material component that is subject to the HMR, there is not a size or capacity limit for the motor of a wheelchair or other battery-powered mobility aids carried by aircraft passengers or crewmembers under the HMR. Q2. What is the "size" limit for a lithium ion battery that powers a wheelchair or other mobility aid when it is carried in checked baggage or carry-on baggage, and when carried as a spare? A2. We preface our response by noting that lithium batteries that are not packed with or contained in equipment such as a wheelchair are not allowed in checked baggage. With respect to your question; in general, the HMR do not limit the size of a lithium ion battery installed in a wheelchair or other mobility aid carried aboard an aircraft as checked baggage. See § 175.10(a)(17).#

Page 2However, where a wheelchair or mobility aid is designed to allow the removal of the lithium ion battery by the user, the battery must be removed and carried aboard the aircraft in carry-on baggage only. Under this condition, the lithium ion battery may not exceed 300 watt-hours (Wh; and a maximum of one spare lithium ion battery not exceeding 300 Wh or two spares each not exceeding 160 Wh each may be carried in carry-on baggage only (see § 175.10(a)(17)(v))). I hope this answers your inquiry. If you need additional assistance, please contact this Office again. Sincerely, LDirk DekKinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3================= ===JOSEPH TSIYON| ==: == 1415 N. Rose Street Phone: (480) 949-0894 Tempe, Arizona 85281 Tsiyoni@Cox.Net Mitchell December 17, 2015 §173.185 Mr. Duane Pfund Batteries International Standard Coordinator Standard and Rules Division, U.S. Department of Transportation 16-0006 Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE, Washington, DC 20590 Re: A. HANDICAP SCOOTER: MOTOR CAPACITY B. LITHIUM BATTERY CAPACIST HELD SEPARATELY (Not on scooter) Dear Mr. Pfund: May I ask you to please clarify the rules about the size/capacity of motor and battery allowed on a handicap or any scooter delivered in an aircraft. A. A MOTOR ON A HANDICAP SCOOTER: is there any limit on capacity, e.g. 350W? B. IF A Lithium Battery is carried to the cabin, or checked in: Since there is no limit if the battery is attached to the scooter, protected from turn- on: i. What is the capacity limit (ELC, and/or WATT) if any if carried to the cabin of an aircraft? ii. What is the capacity limit (ELC, and/or WATT) if any if the battery is checked in? (Normally that would be for a spare battery, e.g. 16Ah., which is more than 25 ELC, or 300 WH. Please kindly as soon as possible. I appreciate your help and thank you very much for quick response. Respectfully, misplea Joseph Tsiyoni#