Interpretation Response #24-0062
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Republic Airways
Individual Name: Rob Hall
Location State: IL Country: US
View the Interpretation Document
Response text:
October 1, 2024
Rob Hall
Manager of Dangerous Goods and Environmental Compliance
Republic Airways
8909 Purdue Road
Suite 300
Indianapolis, IN 46268
Reference No. 24-0062
Dear Mr. Hall:
This letter is in response to your July 10, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of a portable electronic device powered by a lithium metal battery on a passenger aircraft in accordance with § 175.10 for professional purposes. Specifically, you ask whether an aircraft maintenance technician can utilize the § 175.10(a)(18) personal device exception to bring a small aircraft component that contains a 0.12g lithium metal button cell battery contained in equipment in the cabin of a revenue or repositioning/ferry flight when traveling to perform repairs on an out of service aircraft.
The answer is no. Section 175.10(a)(18) applies to passengers, crewmembers, and air operators carrying portable electronic devices containing a battery when carried by passengers or crew members for personal use. Your scenario describes an aircraft component for non-personal use, and therefore does not qualify for the purposes of the exception under § 175.10(a)(18). Section 175.8(a)(3) specifies that items of replacement (company material), like the repair part you describe, must be transported in accordance with the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
175.8(a)(3), 175.10, 175.10(a)(18)