Interpretation Response #15-0069 ([Mr. Joseph Tsiyoni])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Joseph Tsiyoni
Location State: AZ Country: US
View the Interpretation Document
Response text:
June 15, 2015
Joseph Tsiyoni
1415 N. Rose Street
Tempe, AZ 85281
Ref. No.: 15-0069
Dear Mr. Tsiyoni:
This is in response to your letter dated April 7, 2015, 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. In your letter you note that most mobility aids contain a lithium ion battery that is removable but not without significant efforts. You raise a concern that because the lithium ion batteries are technically removable by the consumer, the watt-hour limit in
§ 175.10(a)(17)(v) applies. You request confirmation of your understanding of a previous letter (14-0066) that specified that mobility aids containing lithium batteries that are not specifically designed to be removed by the user are not subject to battery size limits.
Your understanding of the requirements of § 175.10(a)(17) and 14-0066 are correct. In general, § 175.10(a)(17) does not limit the size of the lithium ion battery installed in a wheelchair or other mobility aid when the lithium battery powered mobility aid meets certain conditions outlined in § 175.10(a)(17) and the mobility aid is carried as checked baggage.
PHMSA created a separate authorization that permits the transport of a mobility aid as carry-on baggage (see final rule 76 FR 3308; January 19, 2011). A lithium battery powered mobility aid authorized in carry-on baggage must be specifically designed to allow its battery to be removed and carried separately. This configuration is different than traditional mobility aids in which the battery is not intended to be frequently removed and reinstalled.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division
175.10(a)(17)(v), 175.10(a)(17)
Regulation Sections
| Section | Subject |
|---|---|
| 175.10 | Exceptions for passengers, crewmembers, and air operators |