Interpretation Response #14-0028 ([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 27, 2014
Mr. Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Dr.
Morrisville, NC 27560
Ref. No.: 14-0028
Dear Mr. Romach:
This is in response to your letter dated February 7, 2014, requesting clarification of 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 (ICAO TI) relating to competent authority approvals that are necessary for the transportation of lithium ion batteries. Specifically, you ask if a U.S. competent authority approval is required for a lithium battery weighing greater than 35 kg that is prepared in accordance with the ICAO TI and shipped into the United States from another country. Stated another way, is a competent authority approval issued from the country of origin of the lithium battery shipment sufficient to comply with the HMR?
A U.S. competent authority approval is necessary for shipments of lithium batteries transported within the United States by aircraft, when offered in accordance with special provision A99 of the ICAO TI. Section 171.24(b)(2) requires any person who offers for transportation or transports a hazardous material in accordance with the ICAO TI to also comply with the quantity limits prescribed in the ICAO TI for transportation by passenger-carrying or cargo aircraft, as applicable. The ICAO TI, in special provision A99, only requires approval from the state of origin for a lithium battery that is of a type proven to meet the requirements of the tests in the UN Manual of Tests and Criteria, but exceeds 35 kg in weight. However, the additional requirement in § 171.24(b)(2) necessitates the need for an approval from the U.S. competent authority.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
171.24
Regulation Sections
| Section | Subject |
|---|---|
| 171.24 | Additional requirements for the use of the ICAO Technical Instructions |