44 Blue Productions LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE MAY 1 8 2018 Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration Mark Hamaguchi Vice President of Production Management 44 Blue Productions LLC 3900 W. Alameda Avenue 7h Floor Burbank, CA 91505 Reference No. 16-0174 Dear Mr. Hamaguchi: This letter is in response to your October 21, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to exceptions for passengers, crewmembers, and air operators under § 175.10. Specifically, you ask about the quantity of nickel metal hydride batteries permitted in checked baggage. In accordance with § 175.10(a)(18), the HMR authorize the carriage of portable electronic devices containing dry cells or batteries and spare dry cells or batteries for these devices, when carried by passengers or crew members for personal use. Provided each spare battery is individually protected to prevent damage and short circuit, there would be no quantity or watt in checked or carry-on baggage. hour limitations on nickel metal hydride batteries that passengers or crew members could carry Some examples of packaging methods to prevent short circuiting may include: packaging each battery in fully enclosed inner packages made of non-conductive material, packaging batteries in a manner to prevent contact with other batteries, devices or conductive materials, and ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means. In addition to the transportation safety requirements pertaining to these devices, there may be additional security requirements issued by the Transportation Security Administration.#

Page 2I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, 7, Alense Tosan T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3Zehman 175,10 Goodall, Shante CTR (PHMSA) Exceptions From: Sent: Rivera, Jordan CTR (PHMSA) 16-0174 To: Friday, October 21, 2016 4:23 PM Subject: Hazmat Interps FW: 44 Blue Productions- Nickel Metal Hydride Batteries Hi Shante/Alice, Please submit this as a letter of interpretation. I spoke with Mr. Hamaguchi. Please let me know if you have any questions. Thanks, Jordan Sent: Friday, October 21, 2016 4:00 PM From: Mark Hamaguchi [mailto:mhamaguchi@44blue.com] To: INFOCNTR (PHMSA) Cc: Ed Brotherton Subject: Re: 44 Blue Productions- Nickel Metal Hydride Batteries Thank you Jordan. Ed mentioned that there are no restrictions but / wanted it in writing for our records. Mark Hamaguchi 44 Blue Productions LLC 3900 W. Alameda Ave., 7th Floor Burbank, CA 91505 818-760-4442 Thank you, Mark Mark Hamaguchi |V.P. of Production Management|44 Blue Productions, Inc. [818.760.4442| www.44blue.com 44 BLUE From: "INFOCNTR (PHMSA)" < INFOCNTR.INFOCNTR@dot.gov> Date: Friday, October 21, 2016 at 12:37 PM To: Mark Hamaguchi <mhamaguchi@44blue.com> Subject: RE: 44 Blue Productions- Nickel Metal Hydride Batteries Dear Mark, 1#

Page 4. We have received your request for a written letter of interpretation regarding the hazardous materials regulations (49 CFR Parts 171-180). The hazardous materials regulations are available at the following URL: http://phmsa.dot.gov/regulations In order to process your request, please respond to this email with your full contact information (mailing address, telephone number). You may contact the Hazardous Materials Information Center at +1 202-366-4488 with questions. Please allow a minimum of 8 weeks before contacting the Office of Hazardous Materials Standards (OHMS) for a status on written letters of interpretations. Delivery time of a written interpretation can vary markedly based on topic appropriate response. complexity and the depth of review necessary by OHMS Divisions and modal administrations (e.g., FAA) to ensure an Sincerely, Jordan, Hazardous Materials Specialist with 49 CFR 105.20. http://phmsa.dot.gov/hazmat/regs/interps An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance From: Mark Hamaguchi [mailto:mhamaguchi@44blue.com] To: INFONTR (PHMSA ent: Friday, October 21, 2016 2:33 Pr Cc: Ed Brotherton Subject: Re: 44 Blue Productions- Nickel Metal Hydride Batteries Hello PHMSA, Hope this email finds you well. My Tech Manager, Ed Brotherton, spoke with Jordan at your organization yesterday. We were interested in finding out if there are restrictions on the quantity that is allowed for CHECK- IN BAGGAGE on passenger planes. FAA Special Agent Judy Ann Regan confirmed that Nickel Metal Hydride batteries should be fine to be checked-in but suggested 1 reconfirm with your organization. Can you assist... see below: October 20,2016 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 Dear Hazardous Material Department, 2#

Page 5As mentioned in our voice-mail, 44 Blue Productions, LLC produces a variety of television series all over the country. In doing so, we travel with camera, audio and lighting gear that use a variety of battery types. Since lithium batteries have been causing problems and have travel restrictions, we've been researching alternative options for batteries that are allowed to be checked-in as baggage on passenger aircrafts. In speaking with the FAA, it seems that Nickel Metal Hydride batteries are acceptable to be checked-in on passenger planes without restrictions. We would like to request a written interpretation of regulation 175.10 (a) 18 regarding the number (quantity) of Nickel Metal Hydride batteries that are allowed in checked baggage. We have been working with FAA Special Agent Judy Ann Regan with our research and she suggested contacting you to re-confirm. Should you have any questions or require additional information, please feel free to reach out to me. Look forward to hearing from you. Thank you, Mark Hamaguchi Vice President, Production Management 818-760-4442 Mark Hamaguchi | V.P. of Production Management| 44 Blue Productions, Inc. |818.760.4442| www.44blue.com 44 BLUE From: Ed Brotherton <EBrotherton@44blue.com> Date: Wednesday, October 19, 2016 at 11:45 AM To: Mark Hamaguchi <mhamaguchi@44blue.com> Subject: Email address to the Hazmat Info Center Infocntr@dot.gov Ed Brotherton | Technical Manager |44 Blue Productions, Inc. |818.760.4442 ext. 133| www.44blue.com 44 BLUE 3#