Interpretation Response #07-0234 ([Spectrum Brands, Inc.] [Ms. Tracy Staidi Wrycha])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Spectrum Brands, Inc.
Individual Name: Ms. Tracy Staidi Wrycha
Location State: WI Country: US
View the Interpretation Document
Response text:
March 14, 2008
Ms. Tracy Staidl Wrycha
Spectrum Brands, Inc.
601 Rayovac Drive
Madison, WI 53711-2497
Ref. No.: 07-0234
Dear Ms. Wrycha:
This is in response to your December 12, 2007 letter concerning the transportation by aircraft of electric shaving, grooming, and epilating devices containing nickel cadmium or nickel metal hydride batteries. The shipment is prepared in accordance with the International Civil Aviation Organization's (ICAO) Technical Instructions. As described in your letter, the batteries are contained in the device, the device is blister-packed, and the blister pack is placed in a strong outer package. Your questions are paraphrased and answered as follows:
Q1. Under ICAO, does Special Provision A123 prohibit the transportation of nickel cadmium or nickel metal hydride batteries installed in equipment?
A1. No. Provided the device does not have the potential of dangerous evolution of heat when activated, the batteries may be installed.
Q2. Does the device, as packaged, conform to ICAO Special Provision A123?
A2. Yes. Based on the description of your packaging and the photographs enclosed with your letter, the devices are packaged in conformance with ICAO Special Provision A123.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
171.11