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Interpretation Response #10-0071 ([Holland & Knight Law Firm] [Mr. Jonathan Epstein])

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

Interpretation Response Details

Response Publish Date:

Company Name: Holland & Knight Law Firm

Individual Name: Mr. Jonathan Epstein

Location State: DC Country: US

View the Interpretation Document

Response text:

April 30, 2010




Mr. Jonathan Epstein


Holland & Knight Law Firm

2099 Pennsylvania Ave. N.W.

Suite 100

Washington, DC 20006

Ref. No. 10-0071:

Dear Mr. Epstein:

This responds to your March 26, 2010 email requesting clarification of the requirements for shipping lithium batteries in accordance with Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI). Specifically, you ask if the information required in the document accompanying the shipment may be printed directly onto packages or printed on a label affixed to the packages.

The answer is no. Both the HMR and the ICAO TI require a paper document indicating that the package contains lithium batteries and special procedures should be followed if the package is damaged to accompany the shipment. Alternatively this document may be transmitted separately to the carrier in a manner that permits the information to be produced as a paper document without delay.

I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

173.185, 172.200


Regulation Sections

Section Subject
172.200 Applicability
173.185 Lithium cells and batteries