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Interpretation Response #08-0236 ([Obadal, Filler, MacLeod & Klein, P.L.C.] [Mr. Colin P. Carroll])

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

Interpretation Response Details

Response Publish Date:

Company Name: Obadal, Filler, MacLeod & Klein, P.L.C.

Individual Name: Mr. Colin P. Carroll

Location State: VA Country: US

View the Interpretation Document

Response text:

October 31, 2008



Mr. Colin P. Carroll
Obadal, Filler, MacLeod & Klein, P.L.C.
117 North Henry Street
Alexandria, VA 22314-2903

Ref. No. 08-0236

Dear Mr. Greene:

This responds to your letter dated October 1, 2008 concerning the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180) to offerors of small lithium cells and batteries. Specifically, you seek clarification of the training requirements and gross weight limitations outlined in Part 172.

Lithium cells and batteries, including cells and batteries packed with or contained in equipment, that meet the requirements of Special Provision (SP) 188 are not subject to any other requirements of the HMR. Therefore, persons who ship small lithium cells and batteries under the provisions of SP 188 are not subject to the formal training requirements of Subpart H in Part 172 or the aircraft quantity limitations outlined in § 172.102, Special Provisions A100, A101, A103 and A104. A person who offers small lithium cells and batteries for transportation under SP 188 must ensure that the cells or batteries comply with each of the requirements of SP 188.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.


Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries