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Interpretation Response #14-0162 ([Global Satellite Engineering] [Mr. Scott Walters])

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

Interpretation Response Details

Response Publish Date:

Company Name: Global Satellite Engineering

Individual Name: Mr. Scott Walters

Location State: FL Country: US

View the Interpretation Document

Response text:

December 23, 2014

Mr. Scott Walters
Global Satellite Engineering
1901 S. Andrews Ave
Fort Lauderdale, Fl 33316

Ref. No. 14-0162

Dear Mr. Walters:

This is a response to your August 18, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the shipment of equipment containing lithium ion batteries.  In your incoming letter, you provide an example of a marking you intend to place on the outside of the packages containing your equipment.  Specifically, you request verification and certification that this marking meets the requirements of § 173.185(c)(4).

It is not the role of this Office to certify hazardous materials shipping labels and package markings for use.  It is the shipper’s responsibility to ensure compliance.  Nonetheless, based on the example you provide, it is the opinion of this Office that the marking would satisfy the requirements of § 173.185(c)(4) and contains the required information to be shipped by air domestically and internationally under the International Civil Aviation Organization (ICAO) Technical Instructions (TI) provided the marking, when applied to the package, meets the dimensional (120 x 110mm) and color requirements (black symbols and text, red border) of § 173.185(c)(4).  We do note that while it is not specifically required, if shipped internationally, a mark which includes the international access code [or “+” (plus) sign] and country calling code may eliminate any frustration of shipment and ease the accessibility to information about the battery shipment.

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


Dirk Der Kinderen
Acting Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.185 Lithium cells and batteries