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Interpretation Response #04-0283 ([ATA HMC COMAT Taskforce] [Mr. Les Ado])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: ATA HMC COMAT Taskforce

Individual Name: Mr. Les Ado

Location State: OK Country: US

View the Interpretation Document

Response text:

Dec 15, 2005


Mr. Les Ado                 Reference No. 04-0283
Chairman, ATA HMC COMAT Taskforce
3900 North Mingo Road
P.O. Box 582809
Tulsa, OK 74116

Dear Mr. Adolph:

This is in response to your letter and subsequent conversation with a member of my staff concerning the transportation of primary lithium batteries and cells aboard passenger aircraft in accordance with the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) adopted under Docket HM-224E (December 15, 2004). You state that in order to ensure proper operation of a defibrillator during flight, in particular in order to be able to service multiple patients on a given flight, it is necessary to transport the defibrillator with an extra battery supply. You ask if the transportation of a defibrillator with an extra battery supply conforms to the requirement in Special Provision A101(b) that states that the package may contain no more than the number of lithium batteries or cells necessary to power the intended piece of equipment

The answer is no. The HMR as amended by the HM-224E interim final rule, impose a limited prohibition on the offering for transportation and transportation of primary (non-rechargeable) lithium batteries and cells and equipment containing or packed with large primary lithium batteries as cargo aboard passenger-carrying aircraft. This interim final rule applies to both foreign and domestic passenger-carrying aircraft entering, leaving, or operating in the United States and to persons offering primary lithium batteries and cells for transportation as cargo on any passenger-carrying aircraft. The “extra” primary lithium battery is not necessary to operate the device. Therefore, the “extra” primary lithium battery for your defibrillator may not be transported in accordance with Special provision Al0l.

I hope this information is helpful. Please contact us if you require additional assistance




Susan Gorsky
Acting Director
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries