Republic Airways — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 October 1, 2024 Rob Hall Manager of Dangerous Goods and Environmental Compliance Republic Airways 8909 Purdue Road Suite 300 Indianapolis, IN 46268 Reference No. 24-0062 Dear Mr. Hall: This letter is in response to your July 10, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of a portable electronic device powered by a lithium metal battery on a passenger aircraft in accordance with § 175.10 for professional purposes. Specifically, you ask whether an aircraft maintenance technician can utilize the § 175.10(a)(18) personal device exception to bring a small aircraft component that contains a 0.12g lithium metal button cell battery contained in equipment in the cabin of a revenue or repositioning/ferry flight when traveling to perform repairs on an out of service aircraft. The answer is no. Section 175.10(a)(18) applies to passengers, crewmembers, and air operators carrying portable electronic devices containing a battery when carried by passengers or crew members for personal use. Your scenario describes an aircraft component for non-personal use, and therefore does not qualify for the purposes of the exception under § 175.10(a)(18). Section 175.8(a)(3) specifies that items of replacement (company material), like the repair part you describe, must be transported in accordance with the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Alexander Wolcott Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 224-0062 Jacobson Jones, Jessie Jane CTR (PHMSA) From: INFOCNTR (PHMSA) Sent: Friday, July 12, 2024 11:58 AM To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Request for Interpretation Attachments: 49 CFR 175.10 Interpretation Request.pdf Follow Up Flag: Follow up Flag Status: Flagged Hello Alice, Please see the attached interpretation request. Let us know if you need anything. Sincerely, Janaye From: Hall, Robert L <rhall@rjet.com> Sent: Wednesday, July 10, 2024 9:03 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request for Interpretation CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Republic Airways is respectfully submitting this request for formal interpretation. We look forward to your response. Thank you in advance. Regards, Rob Rob Hall ASQ CQA Manager of Dangerous Goods and Environmental Compliance 317-471-2754 office rhall@rjet.com 1#

Page 37/10/2024 Mr. Shane Kelley Director, Standards and Rulemaking Division U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Good afternoon, Mr. Kelley only a small Regards Regards Rob Hall Manager of Dangerous Goods and Environmental Compliance 317-471- rhall@rjet.com#