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Interpretation Response #14-0013 ([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: Adrian Shipman

Location State: IL Country: US

View the Interpretation Document

Response text:

June 5, 2014

Adrian Shipman
809 E. Moneta Avenue
Peoria Heights, Il   61616

Ref. No. 14-0013

Dear Adrian Shipman:

This responds to your December 4, 2013 request for clarification of the packing instructions for lithium batteries under the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI) and a previous interpretation (Ref No. 12-0261).  Specifically, you seek clarification of Packing Instruction 967 (PI 967) Section II applicable to lithium ion batteries contained in equipment.  PI 967 states “each package containing more than 4 cells or more than 2 batteries installed in equipment must be labeled with a lithium battery handling label.”  PI 967 also limits the net quantity of lithium ion cells or lithium ion batteries to 5 kg per package.  Your questions are paraphrased and answered as follows:

Q1.  Does PI 967 Section II refer to the number of cells or batteries allowed in the package or piece of equipment (i.e., do the 4 cells or 2 batteries refer to the number of cells or batteries allowed in the package or allowed in a piece of equipment)?

A1.  PI 967 refers to the allowable number of cells or batteries that are contained in equipment.  This limits the total number of cells or batteries that may be contained in any one package but would permit a piece of equipment to contain multiple cells or batteries or a package to contain multiple pieces of equipment.  For example, if you have a cellular phone powered by a single cell lithium ion battery, up to four cellular phones can be placed into this package without a requirement to display the lithium battery handling label.  However, if five cellular phones are placed in this package, then you would have to display the lithium battery handling label.   

Q2.  A recent PHMSA Letter of Interpretation (Ref. No. 12-0261) stated “[t]he ICAO TI provides an exception for equipment containing four or less cells or two or less batteries from the requirement to label packages with a battery handling label and accompanying documentation.”  You ask if this interpretation (Ref. No. 12-0261) refers to the number of batteries allowed in the equipment with a max net of 5kg per package.

A2.   Ref. No. 12-0261 discussed an example of a single piece of equipment that could contain up to three lithium metal button cell batteries.  The total net mass of the button cells contained in the equipment was 3.3 kg.  As stated in that letter, the lithium battery handling label would not be required because the package contained less than the 4 cell limit and the total net mass of the lithium metal cells in the package is less than 5 kg. 

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


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

171.23, 171.24


Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
171.24 Additional requirements for the use of the ICAO Technical Instructions