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Interpretation Response #15-0043 ([Ingram Micro Inc.] [Mr. Glenn Williams])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ingram Micro Inc.

Individual Name: Mr. Glenn Williams

Location State: NY Country: US

View the Interpretation Document

Response text:

October 20, 2015

Mr. Glenn Williams
Ingram Micro Inc.
1759 Wehrle Drive
Williamsville, NY 14221

Ref. No. 15-0043

Dear Mr. Williams:

This is a response to your March 4, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the transportation of lithium batteries under § 173.185(c). Specifically, you request confirmation that electronic manifests corresponding to your shipments are not required to be annotated with the required language in § 173.185(c)(4)(ii), stating the package complies with that paragraph ((c)(4)), or the applicable ICAO Packing Instruction.

In accordance with § 173.185(c)(4)(ii), when an air waybill (AWB) is used, an indication on the air waybill of compliance with paragraph (c)(4) (or the applicable ICAO Packing Instruction) must be included. In your email and conversation with a member of my staff, you state that you use an electronic manifest and not an AWB for shipments of lithium batteries. This document includes information regarding the shipment, such as the number of packages, but does not include an indication of the commodity. Additionally, you state that the electronic manifest contains the information normally found on an AWB (i.e., contractual information between the shipper and carrier).

Although not defined in the HMR, we believe industry practice is for an AWB to include a description of the nature of goods in the shipment. The freight forwarder or air carrier that accepts your shipments are in the best position to inform you of whether an AWB (or information contained within the AWB) is required with your shipment(s). If so, the AWB annotation in § 173.185(c)(4)(ii) is required.

The required annotations (i.e., the marking on the box and the indication on AWB) communicate to the air carrier that the package contains lithium batteries and is in compliance with the HMR without more extensive paperwork. They are both important hazard communications to air carriers. Air carriers cannot manage risks to their aircraft if they cannot identify such risks. I encourage you to inquire with your freight forwarder and/or air carrier to ensure that your shipments are offered in compliance.

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

173.185(c), 173.185(c)(4)(ii)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries