Interpretation Response #15-0027 ([Texas Instruments Incorporation] [Mr. Louis Le])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Texas Instruments Incorporation
Individual Name: Mr. Louis Le
Location State: TX Country: US
View the Interpretation Document
Response text:
November 4, 2015
Mr. Louis Le
Product Stewardship Manager
Education Technology
Texas Instruments Incorporated
12500 TI Boulevard
Dallas, TX 75243
Reference No. 15-0027
Dear Mr. Le:
This is in response to your e-mails and the supplemental information you provided requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to properly shipping calculators that contain lithium-ion batteries. You state some of your company’s calculators that contain these batteries are routinely frustrated in transit. Specifically, you ask if your company’s products meet the conditions of § 173.185(c) of the HMR and Special Provision 188 of the International Maritime Dangerous Goods (IMDG) Code.
You provided the material safety data sheet (MSDS) of the lithium-ion batteries installed in the calculators. It describes the battery as a 3.7 Volt, 4.44 Watt hour (Wh), lithium ion battery Model Nos. P11P35-09-N01 and P11P35-11-N01, manufactured by Samsung SDI Company, Ltd. The MSDS indicates that the batteries are of a type proven to meet the requirements of each test in the United Nations Manual of Tests and Criteria, Part III sub-section 38.3. You further state the calculators containing installed batteries are packed in blister packs and placed in a strong outer packaging.
The information you provided indicates that your shipments of lithium ion batteries contained in equipment meet the cell/battery testing, size, and packaging requirements of § 173.185(c) and Special Provision 188 of the IMDG Code. Hazard communication
requirements in § 173.185 and IMDG Code Special Provision 188 apply to packages that contain more than four lithium cells or two lithium batteries contained in equipment.
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.185(c), 173.185
Regulation Sections
| Section | Subject |
|---|---|
| 173.185 | Lithium cells and batteries |
| 173.185 | Lithium cells and batteries |