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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #16-0174

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

Interpretation Response Details

Response Publish Date:

Company Name: 44 Blue Productions LLC

Individual Name: Mark Hamaguchi

Location State: CA Country: US

View the Interpretation Document

Response text:

May 18, 2018

Mark Hamaguchi
Vice President of Production Management
44 Blue Productions LLC
3900 W. Alameda Avenue
7th Floor
Burbank, CA 91505

Reference No. 16-0174

Dear Mr. Hamaguchi:

This letter is in response to your October 21, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to exceptions for passengers, crewmembers, and air operators under § 175.10. Specifically, you ask about the quantity of nickel metal hydride batteries permitted in checked baggage.

In accordance with § 175.10(a)(18), the HMR authorize the carriage of portable electronic devices containing dry cells or batteries and spare dry cells or batteries for these devices, when carried by passengers or crew members for personal use. Provided each spare battery is individually protected to prevent damage and short circuit, there would be no quantity or watt hour limitations on nickel metal hydride batteries that passengers or crew members could carry in checked or carry-on baggage.

Some examples of packaging methods to prevent short circuiting may include: packaging each battery in fully enclosed inner packages made of non-conductive material, packaging batteries in a manner to prevent contact with other batteries, devices or conductive materials, and ensuring exposed terminals or connectors are protected with non-conductive caps, non-conductive tape, or by other appropriate means.

In addition to the transportation safety requirements pertaining to these devices, there may be additional security requirements issued by the Transportation Security Administration.

I hope this information is helpful. Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
175.10 Exceptions for passengers, crewmembers, and air operators