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Interpretation Response #08-0161 ([Portable Rechargeable Battery Association] [Mr. George Kerchner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Portable Rechargeable Battery Association

Individual Name: Mr. George Kerchner

Location State: DC Country: US

View the Interpretation Document

Response text:

July 29, 2008

Mr. George Kerchner

Executive Director

Portable Rechargeable Battery Association

1776 K Street, NW

Washington, DC 20006

Ref. No.: 08-0161

Dear Mr. Kerchner:

This is in response to your June 3, 2008 electronic mail requesting clarification of the packaging requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the various international dangerous goods regulations pertaining to lithium batteries.

Specifically, you ask if a shipper may use strong outer packagings, protective enclosures or pallets instead of UN combination packages provided certain requirements are met.

As provided by § 173.185(g) and Packing Instruction 903 of the International Civil Aviation Organization Technical Instructions and the International Maritime Dangerous Goods Code, batteries employing a strong, impact-resistant outer casing and exceeding a gross weight of 12 kg (26.5 lbs.), and assemblies of such batteries, may be packed in strong outer packagings, in protective enclosures (for example, in fully enclosed wooden slatted crates) or on pallets. Batteries must be secured to prevent inadvertent movement, and the terminals may not support the weight of other superimposed elements. Batteries packaged in this manner are not subject to specification packaging requirements but are subject to the other requirements of § 173.185(a) or Packing Instruction 903 including short circuit protection and design type testing.

Batteries packaged in the manner described above may be transported by highway, rail, and vessel. Such batteries are not permitted for transportation by passenger aircraft, and may be transported by cargo aircraft only if approved by the Associate Administrator prior to transportation.

I hope this information is helpful. Please contact us if you require additional assistance.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries