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Interpretation Response #08-0006 ([SIEMENS Building Technogies, Inc.] [Mr. Adam Jablonski])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: SIEMENS Building Technogies, Inc.

Individual Name: Mr. Adam Jablonski

Location State: IL Country: US

View the Interpretation Document

Response text:

March 21, 2008


Mr. Adam Jablonski

SIEMENS Building Technologies, Inc.

1000 Deerfield Parkway

Buffalo Grove, IL 60089

Ref. No.: 08-0006

Dear Mr. Jablonski:

This is in response to your December 11, 2008 letter regarding requirements applicable to the transportation of lithium batteries installed in and packaged with equipment under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as amended in Docket HM 224C and HM 224E, published August 9, 2007 (72 FR 44929). Specifically, you ask if the exception from the prohibition on the transport of primary lithium batteries by passenger aircraft under Special Provision 188 applies to batteries packaged with equipment.

The answer is yes. The exception from the prohibition on the transport of primary lithium batteries by passenger aircraft in Special Provision 188 under paragraph a.(2) applies to batteries packed "in" as well as "with" equipment.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.102 SP 188 173.185

Regulation Sections

Section Subject
172.102 Special provisions
173.185 Lithium cells and batteries