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Interpretation Response #14-0012 ([Mr. Adrian Shipman])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Adrian Shipman

Location State: IL Country: US

View the Interpretation Document

Response text:

March 12, 2014

Mr. Adrian Shipman
809 E. Moneta Avenue
Peoria Heights, IL   61616

Ref. No. 14-0012

Dear Mr. Shipman:

This responds to your December 4, 2013 request for clarification of shipping lithium batteries under 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.  You indicate you have a tablet computer powered by a lithium ion battery.  Additionally, you indicate the tablet containing a lithium ion battery is packaged in the original packaging from the manufacturer and is shrink-wrapped.  You also indicate that the package meets packaging requirements in subpart B of part 173 of the HMR and it is your understanding that marking or labeling requirements do not apply.  Your questions are paraphrased and answered as follows:

Q1.  May the proper shipping name and UN identification number “Lithium ion batteries contained in equipment, UN3481” be used for ground shipment of this material?

A1.  The answer is yes.  The proper shipping name and UN identification number, “Lithium ion batteries in contained in equipment, UN 3481” is authorized for ground shipments in the United States.  Notice No. 09-04 [74 FR 42952], published August 25, 2009, provides approval to all shippers to use this international shipping name domestically.  

Q2.  Can the manufacturer’s packaging be considered the outside packaging if it has the manufacturer’s logo and picture of the tablet on the outside?  

A2.   The answer is yes.  The original manufacturer’s packaging may be used as the outside packaging for transport provided the packaging meets the packaging requirements in subpart B of part 173. The packaging must be designed and constructed so that the packaging can withstand normal conditions of transportation.  Additionally, it should be noted that if your batteries meet the size conditions for small lithium ion batteries contained in equipment and comply with the applicable provisions in § 172.102(c), Special Provision 188, the tablet computer described in your letter would not be subject to any other requirements of the HMR.  

I hope this answers your inquiry.  If you need additional assistance, please contact this office at (202) 366-8553.

Sincerely,

Robert Benedict
Chief, Regulations Development Branch
Standards and Rulemaking Division

172.102 SP 188

Regulation Sections

Section Subject
173.185 Lithium cells and batteries