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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.


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