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Interpretation Response #13-0119 ([Kurt J. Lesker Company] [Mr. Lew Miller])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kurt J. Lesker Company

Individual Name: Mr. Lew Miller

Location State: PA Country: US

View the Interpretation Document

Response text:

September 6, 2013

Mr. Lew Miller
Manager, U.S. Logistics & Warehouse
Kurt J. Lesker Company
1925 Route 51
Jefferson Hills, PA  15025

Reference No. 13-0119

Dear Mr. Miller:

This is in response to your recent e-mails and telephone conversations with a member of my staff regarding the types of packagings your company may use to package eight, round wafer disks composed of 99.9 percent “UN 1415, Lithium, Division 4.3 (dangerous when wet), PG I” by cargo-only aircraft from the United States to Germany under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).  

You state each wafer contains 0.15 kg of lithium, measures 349.8 mm x 135.9 mm x 6 mm thick, and weighs 0.149 kg (0.33 pounds).  The wafers are bonded to a backing plate in a manner that prevents the wafers from touching each other and then enclosed in a metal assembly (herein referred to as the “assembly”).  You also state the completed assembly is 64” L x 18” W x 8” H, is not waterproof, and weighs 120 pounds when filled and closed.  You enclosed a material safety data sheet for lithium metal pieces, a schematic drawing of the backing tiles, photographs of the closed assembly, and two potential packaging options you would like validated by this Office.
The assembly you describe in your letter is not an article or device specifically listed by name in the § 172.101 Hazardous Materials Table (HMT) or the Table 3-1, Dangerous Goods List, of the ICAO Technical Instructions.  Rather, it is an article containing a substance (UN1415, Lithium).  Non-bulk packagings authorized by the HMR to package UN 1415, Lithium, for transportation by cargo-only aircraft must conform to the requirements prescribed in §§ 173.27, 173.211, and Special provisions A7 and N45 under § 172.102(c).  In addition, the HMR permit packages offered or intended for transportation by aircraft to, through, or from the U.S. to conform to the International Civil Aviation Organization’s Technical Instructions on the Transport of Dangerous Goods by Air (ICAO Technical Instructions), as limited by Subpart C of 49 CFR Part 171.  Packing Instruction 487 of the ICAO Technical Instructions prescribes that your assembly containing UN 1415, Lithium, 4.3, PG I, may be packaged for cargo-only aircraft in a UN 4D Plywood Box (your self-described Option 1) and would be declared as:

UN1415, Lithium, Division 4.3, PG I, One Plywood Box x 1.22 kg, Packing Instruction 487

The “Option 2” described in your letter, a 6HD2 plastic receptacle with outer plywood box, is also an authorized packaging method under Packing Instruction 487 of the ICAO Technical Instructions.  Please note that regardless of what authorized packaging is used for the assembly, under the ICAO Technical Instructions either the individual wafers or the entire metal assembly must be hermetically sealed (e.g., by taping or threaded closures).

In your letter, you also ask where you might be able to obtain such packagings commercially in dimensions appropriate for the assembly.  PHMSA does not maintain a list of packaging designs from packaging manufacturers; however, it does publish a list of commercial suppliers that includes contact information for several hazardous materials packaging manufacturers.  I have enclosed a copy of this pamphlet for your convenience.  It can also be found on our website at:….  You may want to consider discussing the various packaging options provided by the HMR and the ICAO Technical Instructions with Mr. Benjamin Moore, Engineer, Engineering and Research Division, Office of Hazardous Materials Safety, at (202) 366-4545.  

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


172.101, 173.27, 173.211, 172.102(c) SP A7 and N45

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.211 Non-bulk packagings for solid hazardous materials in Packing Group I
173.27 General requirements for transportation by aircraft