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Interpretation Response #13-0096 ([Manufacturing and Supply Chain Services] [Mr. Todd A. Strobel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Manufacturing and Supply Chain Services

Individual Name: Mr. Todd A. Strobel

Location State: MN Country: US

View the Interpretation Document

Response text:

June 20, 2013


Mr. Todd A. Strobel
Regulatory Compliance Specialist
Manufacturing and Supply Chain Services
3M Center, 225-4S-18
St. Paul, MN 55144-1000

Ref. No.: 13-0096

Dear Mr. Strobel:

This is in response to your May 7, 2013 email 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 certain shipments of lithium batteries be accompanied by a document indicating that the package(s) in that shipment contain lithium batteries, a flammability hazard exists if the package is damaged, that special procedures must be followed in the event a package is damaged and a telephone number for additional information.  Specifically, you ask if this document must follow a particular format.

Both the HMR and the ICAO TI require a document to accompany certain shipments of lithium batteries but do not require a specific format.  Any document that contains all of the required information is acceptable.  This approach provides shippers and carriers with the flexibility to design documents consistent with their own needs.  

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

172.102 SP188, 173.185

Regulation Sections

Section Subject
173.185 Lithium cells and batteries