(Please explain the difference between 2.3.4.7 and 2.3.5.9.)
Q.
I am puzzled and confused reading DGR 2.3.4.7 and 2.3.5.9.
DGR 2.3.4.7 says we can go above 100Wh up to 160Wh with checked or carry-on baggage (no quantity limit??)
DGR 2.3.5.9 seems to limit these items to 100Wh with a maximum of 15 PEDs and 20 spares (airline can approve more)
I am sure there must be a simple explanation. My guess is people transporting large quantities of devices 100Wh or less are limited to the 15/20 quantity restriction (unless airline approves more), while normal everyday passenger transporting a single laptop or camera are ok to go to 160Wh, but it is somewhat confusing. I appreciate a clarification.  (28 Feb 18)
A.
ICAO Technical Instructions (ICAO TI) 2017-2018 clearly differentiate 2.3.4.7 and 2.3.5.9. Per Addendum posted 20 June 2017 to DGR 58th Edition, when transporting as checked baggage, ICAO only designated PEDs to be protected from damage, prevented from unintentional activation, and completely switched off (not in sleep or hibernation mode). ICAO did not include Medical PED (MPED) in this restriction. IATA made the rule more severe by including MPEDs into this requirement.

DGR 2.3.4.7 is titled “Lithium Battery powered Electronic Devices” making the rule only applicable to lithium batteries, whereas 2.3.5.9 is titled “Portable Electronic Devices containing batteries” making the rule applicable to all sorts of batteries including but not limited to lithium batteries as well as all types of dry batteries. ICAO/IATA were aware that they were addressing distinctly different PEDs and MPEDs.

The significant difference between 2.3.4.7 and 2.3.5.9, apart from the larger capacity lithium batteries, is that 2.3.4.7 already requires operator approval. So, if a passenger were to ask to carry a significant number of PEDs, the operator can say “No”. With 2.3.5.9, there was no limit specified so therefore the operator had no way of saying “No”. There was a need to introduce a quantity guideline.

For the limit of 15 PEDs and 20 spare batteries, I’m informed that there was much debate at the DGB (IATA Dangerous Goods Board) on what a reasonable limit for a passenger was, that did not place a large burden on the operator having to issue approvals. I am told that based on some work by a number of the DGB members the number 15 PED was agreed. The consideration of what may be carried by a passenger:
2 mobile phones (1 for personal and 1 for work),
1 tablet,
2 laptops (1 for personal and 1 for work),
1 toothbrush,
1 shaver,
1 watch (e.g. iWatch, fitbit)
1 camera, and
1 special camera (e.g. GoPro, video camera)

For the 20 spare batteries I learned that there was the same consideration. A passenger may have a retail package that contains 10 batteries, so it was decided to 2 packages or 20 batteries as a reasonable limit.

The reason why 2.3.5.9 is intended for all types of batteries including dry batteries is because the DGB decided that the limits 15/20 apply to all type of batteries as passenger and check-in staff may not understand the difference.

Following is a brief summary of 2.3.4.7 and 2.3.5.9.
a) 2,3,4,7 - “Lithium Battery powered Electronic Devices”
PED (including medical devices) with lithium ion/metal batteries are permitted with airline approval with the following limitations:
・lithium metal --- greater than 2g but not exceeding 8g
・lithium ion --- greater than 100Wh but not exceeding 160Wh
・no specific quantity limitation mentioned. When more than reasonable quantity, airline can day “No”.
・if checked in --- PED must be protected and shut-off (not sleeping/hibernating)
・spares must be in carry-on baggage (see 2.3.3.2)

b) 2.3.5.9 “Portable Electronic Devices containing batteries”
PED (including medical devices) using all types of batteries including lithium ion/metal batteries --- no airline approval necessary if within limits:
・lithium metal --- not more than 2g
・lithium ion --- not more than 100Wh
・limited to 15 PEDs and 20 spares --- airline can approve larger quantities.
・if checked in --- PED must be protected and shut-off (not sleeping/hibernating)
・spares must be in carry-on baggage.

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