Applicability of 175.10(a) to Demonstrations and Promotional Shows

This letter is in response to your December 11, 2016, letter requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to exceptions for passengers, crewm
embers, and air operators. You describe in your letter a small lithium metal battery contained in bot
h the EZ-IO Intraosseous Infusion system and the OnControl Driver system, further stating that the
battery meets the requirements of each test in the United Nations (UN) Manual of Testing and Criter
ia Part III, Sub-section 38.3 and contains less than 2 grams of lithium metal. Specifically, you ask if
Teleflex employees are permitted to transport this small lithium metal battery, as well as the devices
in which it is contained, in carry-on baggage aboard a passenger aircraft for the purpose of demons
trations and promotional shows.

The answer is yes, provided Teleflex employees follow the requirements in § 175.10(a)(18). The req
uirements of this section allow a passenger or crew member to carry a medical device containing dr
y cells or dry batteries (including lithium cells or batteries) in either checked or carry-on baggage. S
pare lithium batteries must be individually protected to prevent short circuits (e.g., placing them in o
riginal retail packaging, insulating exposed terminals with tape, or placing each battery in a separate
plastic bag or protective pouch) and must be placed in carry-on baggage only.

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