In regard to Sec. 173.220 (d): Lithium batteries.
I try to keep up with news, and while lithium batteries are energy-dense, I am unaware of incidents in which they have exploded or caught fire in a way that caused significant damage to airlines, people, or equipment in the United States.
A few (defective) batteries showed a propensity to overheat, but the industry has risen to address those issues, and also gone on to develop new technology that will address them even more in the future. This regulation may have been desirable once, but by now it solves no real problems.
But it would have a chilling effect on high-tech business. Probably 50% or more of business travelers on U.S. airlines carry equipment powered by these batteries in their checked or carry-on luggage. This regulation, as worded, would preclude American businesspeople from transporting some of their most important business tools via airplane. The very idea is ludicrous.
And I might point out that they have so far been transporting these computers and business tools via airplane for years now, with no known (to me) significantly adverse effect.
I have several specific objections:
(1) It attempts to address an issue that has probably already been relegated to the past.
(2) It would have a strong chilling effect on American businesses, in regard to their ability to conduct legitimate business while traveling.
(3) I have no care whatever for whether this increases conformity with international, United Nations, or other regulations. We are the United States, we should behave as such, and we should stand up when proposed regulations are, as this one, detrimental to free markets without any commensurate increase in actual safety.
In summary, it's just plain a BAD IDEA. I am frankly astonished that it has been seriously considered. It appears that somebody is behind the times, or perhaps too much influenced by foreign interests.
Anonymous
This is comment on Rule
Hazardous Materials: Revision to Requirements for the Transportation of Batteries and Battery-Powered Devices; and Harmonization With the United Nations Recommendations, InternationalMaritime Dangerous Goods Code, and International Civil Aviation Organization's Technical Instructions; Correction
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