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Interpretation Response #12-0031 ([Wiley Rein LLP] [Mr. George Kerchner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wiley Rein LLP

Individual Name: Mr. George Kerchner

Location State: DC Country: US

View the Interpretation Document

Response text:

May 9, 2012

 

 

 

Mr. George Kerchner
Senior Regulatory Analyst
Wiley Rein LLP
1776 K Street, NW
Washington, DC 20006

Ref. No. 12-0031

Dear Mr. Kerchner:

This responds to your January 24, 2012 email requesting clarification of the 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 Technical Instructions) applicable to the transport of lithium batteries. Your questions are paraphrased and answered below:

Q1: May a lithium battery be placed directly into a UN 4G fiberboard box without any inner packaging in accordance with the requirements of § 173.185(a)(4)?

A1: No. As provided by § 173.185(a)(4), each lithium battery must be packed in an inner packaging in such a manner as to prevent short circuits, including movement which could lead to short circuits. The inner packaging must be packed within a suitable outer packaging, such as a UN 4G fiberboard box, that conforms to the requirements of Part 178 subparts L and M at the Packing Group II performance level.

Q2. May a lithium battery be placed directly into a UN 4G fiberboard box without any inner packaging in accordance with the requirements of Packing Instruction 965, Section I of the ICAO Technical Instructions?

A2. No. Similar to the requirements of § 173.185(a)(4), Packing Instruction 965, Section I of the ICAO Technical Instructions requires each lithium battery to be placed in inner packagings that completely enclose the battery, then placed in an outer package. The completed package must meet the performance requirements at the Packing Group II performance level.

I hope this information is helpful. If you have further questions, please contact this office.

Sincerely,

 

Ben Supko
Acting Chief, Standards Development
Office of Hazardous Materials Standards

173.185

Regulation Sections

Section Subject
173.185 Lithium cells and batteries