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Interpretation Response #11-0074 ([Currie Associates, Inc.] [Mr. Tom Ferguson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Currie Associates, Inc.

Individual Name: Mr. Tom Ferguson

Location State: NY Country: US

View the Interpretation Document

Response text:

May 19, 2011


Mr. Tom Ferguson
Technical Consultant
Currie Associates, Inc.
10 Hunter Brook Lane
Queensbury, NY 12804

Ref. No.: 11-0074

Dear Mr. Ferguson:

This responds to your March 29, 2011 letter concerning the aircraft quantity limitations of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium ion batteries contained in equipment. Specifically, you asked if § 172.102(c), special provision A104 limits the total net quantity of lithium ion batteries contained in equipment to 5kg (11 lbs) per package for transport aboard passenger aircraft.

Yes, the HMR limit the net quantity of lithium batteries contained in equipment to 5 kg (11 lbs) per package when transported aboard passenger aircraft. This per package quantity limit is consistent with the quantity limits for lithium ion batteries shipped alone and lithium ion batteries packed with equipment.

I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division.


Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division

172.102 SP A104

Regulation Sections

Section Subject
173.185 Lithium cells and batteries