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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #15-0017 ([Walmart] [Ms. Veronica Wilson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Walmart

Individual Name: Ms. Veronica Wilson

Location State: AZ Country: US

View the Interpretation Document

Response text:

February 19, 2015

Ms. Veronica Wilson
Sr. Strategy Manager, Hazmat Transportation
508 Southwest 8th Street
Bentonville, AR 72716

Ref. No.: 15-0017

Dear Ms. Wilson:

This is in response to your January 22, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the handling document required to accompany packages containing small lithium batteries. Specifically, you ask if the document required by §173.185(c)(3)(ii) must accompany each package within a shipment or if a single document per shipment is permitted and subsequently carried in the cab of the vehicle with the other documents such as the bill of lading. You note that as a retailer with a private fleet, or when using a dedicated third party carrier, you consider all of the material on-board as a single shipment.

Section §173.185(c)(3)(ii) states that "each shipment of one or more packages marked in accordance with this paragraph must be accompanied by a document..." In general, a "shipment" would consist of all materials described on an individual bill of lading. A document as required by 173.185(c)(3)(ii) would be required to accompany each shipment. If all of the materials loaded on a transport vehicle are consigned as a single shipment, then only a single handling document would be required. The document may physically accompany the cargo (such as in a peel away envelope) or be located in the cab of the vehicle in the manner prescribed in §177.817(e).

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


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.185(c)(3)(ii), 177.817(e)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
177.817 Shipping papers