Interpretation Response #11-0124 ([SiGNa Chemistry] [Mr. Michael Lefenfeld])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: SiGNa Chemistry
Individual Name: Mr. Michael Lefenfeld
Location State: NY Country: US
View the Interpretation Document
Response text:
August 22, 2011
Mr. Michael Lefenfeld
President & Chief Executive Officer
SiGNa Chemistry
445 Park Avenue, Suite 1010
New York, NY 10022
Ref. No. 11-0124
Dear Mr. Lefenfeld:
This responds to your May 18, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the transportation in carry-on luggage of fuel cell cartridges by aircraft. Specifically, you request confirmation that a portable electronic device powered by a fuel cell cartridge containing sodium silicide (Division 4.3) may be transported under the provisions of § 175.10(a)(19). You indicate that the fuel cell cartridge conforms to the specifications of IEC/PAD 62282-6-1, which is incorporated by reference in the HMR and provides that "the manufacturer may consider fuels, materials, designs or constructions not specifically dealt with in this document. These alternatives shall be evaluated as to their ability to yield levels of safety equivalent to those prescribed by this standard."
Yes. Based on the information you provide in your letter, the fuel cell powered device is eligible for the exception in § 175.10(a)(19). The fuel cell powered device must comply with all requirements in § 175.10(a)(19), including the manufacturer marking "APPROVED FOR CARRIAGE IN AIRCRAFT CABIN ONLY."
I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.
Sincerely,
Ben Supko
Chief, Standards Development Branch
Standards and Rulemaking Division
175.10
Regulation Sections
| Section | Subject |
|---|---|
| 175.10 | Exceptions for passengers, crewmembers, and air operators |