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Interpretation Response #12-0114 ([Ford Motor Company] [Mr. Grant Haves])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ford Motor Company

Individual Name: Mr. Grant Haves

Location State: MI Country: US

View the Interpretation Document

Response text:

July 16, 2012




Mr. Grant Haves
HazMat Compliance Specialist
Ford Motor Company
5111 Auto Club Drive
Dearborn, MI 48126

Reference No.: 12-0114

Dear Mr. Haves:

This is in response to your May 8, 2012 letter requesting guidance as to whether the most recent amendment to the UN Manual of Tests and Criteria (Amendment 1, to the Fifth Revised Edition, 2011) may be applied for the testing of lithium ion batteries.

As you correctly noted, the UN Manual of Tests and Criteria, Fifth Revised Edition, 2009 is currently cited in § 171.7 of the HMR as incorporated by reference (IBR). Section 171.7 also provides that the matter subject to change is incorporated only as it is in effect on the date of issuance of the regulation referring to that matter.

The codification of this amendment into the HMR will be considered in a future harmonization rulemaking. Until that time, Amendment 1, to the Fifth Revised Edition of the UN Manual of Tests and Criteria cannot be applied to the HMR. However, in accordance with 49 CFR Part 107, an application for a special permit may be submitted, requesting permission to follow the requirements of the amendment.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
171.7 Reference material