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Interpretation Response #13-0034 ([Labelmaster Services] [Mr. Robert Richard   ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Labelmaster Services

Individual Name: Mr. Robert Richard   

Location State: IL Country: US

View the Interpretation Document

Response text:

February 13, 2013



Mr. Robert Richard    
Vice President, Regulatory Affairs
Labelmaster Services
5724 N. Pulaski Rd.
Chicago, IL 60646

Ref. No.: 13-0034

Dear Mr. Richard:

This is in response to your January 14, 2013 email and conversation with a member of my staff 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).  Both the HMR and the ICAO TI require that certain shipments of lithium batteries also have an accompanying document indicating, among other things, that packages contain lithium batteries and that special procedures must be followed in the event of damage to the packages.  Specifically, you ask if this document may be affixed to packages through the use of a pressure sensitive, peel away document.

The answer is yes.  Both the HMR and the ICAO TI require a document to accompany the shipment indicating that the package contains lithium batteries and that special procedures must be followed if the package is damaged.  This requirement may be fulfilled in a number of ways including through the use of a tear away document affixed to each package in the consignment.  

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries