Interpretation Response #00-0105 ([FMC Corporation] [Ms. Helen Hatch])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: FMC Corporation
Individual Name: Ms. Helen Hatch
Location State: NC Country: US
View the Interpretation Document
Response text:
May 16, 2000
Ms. Helen Hatch Ref. No. 00-0105
Product Regulations Specialist, Lithium Division
FMC Corporation
Box 795
Bessemer City, NC 28016
Dear Ms. Hatch:
This is in response to your letter dated April 4, 2000, concerning the packaging requirements for lithium under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions). Your questions are paraphrased and answered as follows:
Question 1: Is lithium metal in sealed pouches, further packed in steel cans, and then packed in a I A2 steel drum, which has been certified as a single packaging for lithium metal, a single or combination packaging?
It is a single packaging. An authorized single packaging for a hazardous material may contain inner receptacles that are compatible with the lading as long as the inner receptacles do not adversely affect the level of performance of the packaging. The packaging would remain marked as a single packaging.
Question 2: Is the above packaging configuration considered a single or combination packaging under the ICAO Technical Instructions?
It is a single packaging. Section 7.1.2.1 of the ICAO Technical Instructions defines a combination packaging as a combination of packages for transport purposes, consisting of one or more inner packages secured in an outer packaging in accordance with the relevant provisions of Part 3. Further, this section defines a single packaging as a packaging that does not require any inner packaging to perform its containment function during transport. The relevant provisions of Part 3 for combination packagings do not apply to your packaging because your package meets the definition of a single packaging.
Question 3: What weight limits apply to the above mentioned packaging?
The 15 kg limit applies to the packaging.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this
Office.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
171.11