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Interpretation Response #14-0188 ([Alaska Air, SEADG] [Mr. Ron Fink])

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

Interpretation Response Details

Response Publish Date:

Company Name: Alaska Air, SEADG

Individual Name: Mr. Ron Fink

Location State: WA Country: US

View the Interpretation Document

Response text:

March 12, 2015

Mr. Ron Fink
Specialist, Dangerous Goods
Alaska Air, SEADG
20833 S. International Blvd., P.O. Box 68900
Seattle, WA 98168-0900

Ref. No. 14-0188

Dear Mr. Fink:

This letter responds to your September 18, 2014 email regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) to lithium metal (cell) batteries.  In your letter, you describe an electronic bag tag that would replace the commonly used paper bag tags attached to checked baggage of the traveling public.  The electronic bag tag is powered by a lithium metal (cell) battery that contains 0.08 grams of lithium metal.  Upon further discussion via telephone conversion with a colleague of yours referenced in the email, we were informed that the electronic bag tag would be given to airline passengers and be in their possession just as any other electronic device a passenger would be traveling with.  Specifically, you request confirmation that carriage of the electronic bag tag aboard passenger aircraft would not be subject to the HMR other than the reporting requirements found in §§ 171.15(b)(6) and 171.16.

Your understanding is generally correct.  We consider the electronic bag tag to be a portable electronic device, and devices powered by lithium batteries are eligible for exception from the HMR under the conditions of § 175.10(a)(18).  The lithium metal content of each (cell) battery to be used in the electronic bag tags is less that the size limit of two (2) grams per battery.  Thus, subject to the forbidden provision for electrical devices in § 173.21, the electronic bag tags you describe are not subject to the HMR provided the requirements of     §§ 171.15 and 171.16 are met.  

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.


Dirk Der Kinderen
Acting Chief, Standard Development
Standards and Rulemaking Division

171.15(b)(6), 171.16, 175.10(a)(18), 173.21, 171.15

Regulation Sections

Section Subject
171.15 Immediate notice of certain hazardous materials incidents
171.15 Immediate notice of certain hazardous materials incidents
171.16 Detailed hazardous materials incident reports
173.21 Forbidden materials and packages
175.10 Exceptions for passengers, crewmembers, and air operators