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Interpretation Response #11-0223 ([Lockheed Martin - Sippican] [Mr. Matthew Sears])

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

Interpretation Response Details

Response Publish Date:

Company Name: Lockheed Martin - Sippican

Individual Name: Mr. Matthew Sears

Location State: MA Country: US

View the Interpretation Document

Response text:

October 27, 2011



Mr. Matthew Sears

EHS Department

Lockheed Martin - Sippican

7 Barnabas Rd.

Marion, MA 02738

Ref. No.: 11-0223

Dear Mr. Sears:

This responds to your September 1, 2011 request for clarification on use of an overpack for the shipment of lithium batteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the 35 kg weight limitation for lithium metal batteries contained in equipment, UN3091, in column 9B of the § 172.101 hazardous materials table and packing instruction 970 of the International Civil Aviation Organizations Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) apply to the weight of individual packages or to the gross weight of all packages contained on the pallet.

The quantity limitations in the HMR apply to the weight of lithium batteries per package. The quantity limitations in the 2011-2012 ICAO Technical Instructions apply to the weight of lithium batteries per piece of equipment. Multiple packages consolidated onto a pallet would constitute an overpack as defined by the HMR and the ICAO Technical Instructions, and the gross weight of the overpack may exceed 35 kg.

I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

172.101, 173.25, 173.185

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table