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Interpretation Response #14-0017 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

May 12, 2014

Mr. Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC  27560

Ref. No.: 14-0017

Dear Mr. Romach:

This is in response to your January 21, 2014 letter requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of prototype lithium batteries.  Specifically, you ask if a prototype lithium battery can be offered for transport and transported by vessel in accordance with special provision 310 of the International Maritime Dangerous Goods (IMDG) Code.

Provided all or part of the movement is by vessel, prototype lithium batteries may be transported in conformance with the requirements of special provision 310 of the IMDG Code and all applicable requirements of Part 171, Subpart C.  Special provision 310 of the IMDG Code states that the testing requirements in chapter 38.3 of the UN Manual of Tests and Criteria do not apply to production runs consisting of not more than 100 lithium cells and batteries, or to pre-production prototypes of lithium cells and batteries when these prototypes are transported for testing, if:

1.     The cells and batteries are transported in an outer packaging that is a metal, plastics or plywood drum or a metal, plastics, or wooden box and that meets the criteria for Packing Group I packagings; and
2.     Each cell and battery is individually packed in an inner packaging inside an outer packaging and is surrounded by cushioning material that is non-combustible and non-conductive.

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



Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries