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Interpretation Response #08-0172 ([National Electrical Manufacturers Association] [Mr. Craig Updyke])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Electrical Manufacturers Association

Individual Name: Mr. Craig Updyke

Location State: VA Country: US

View the Interpretation Document

Response text:

September 10, 2008

Mr. Craig Updyke

National Electrical Manufacturers Association

1300 North 17th Street, Suite 1752

Rosslyn, VA 22209

Ref. No.: 08-0172

Dear Mr. Updyke:

This is in response to your June 30, 2008 letter concerning the packaging of lithium batteries offered for transportation by aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).

A provision contained in Packing Instruction 968 of the ICAO Technical Instructions 2009-2010 edition requires certain packages containing lithium cells or batteries to be capable of withstanding a 1.2 meter drop test without shifting of contents that would allow battery to battery (cell to cell) contact. You ask if this provision is intended to prohibit all contact between batteries while in transport or just contact that could lead to short circuiting.

The intent of this provision is to ensure a package containing lithium cells or batteries is capable of withstanding in any orientation, a drop from a height of 1.2 meters while retaining the cells or batteries in their original orientation. In your letter, you provide an example of AA batteries packed in a blister pack where the insulating jackets of the batteries contact each other but no contact between the conductive terminals occurs. Cells or batteries securely packed in this manner would meet the intent of the requirement.

I hope this answers your inquiry.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries