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Interpretation Response #15-0061 ([Currie Associates, Inc.] [Ms. L'Gena Shaffer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Currie Associates, Inc.

Individual Name: Ms. L'Gena Shaffer

Location State: NY Country: US

View the Interpretation Document

Response text:

June 15, 2015

L'Gena Shaffer
Technical Consultant
Currie Associates, Inc.
10 Hunter Brook Lane
Queesbury, NY 12804

Ref. No.: 15-0061

Dear Ms. Shaffer:

This is in response to your letter dated March 25, 2015 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to packaging of lithium battery powered equipment. You request confirmation of your understanding that lithium batteries contained in equipment are not subject to the requirements for outer packagings when the equipment provides equivalent protection for the lithium battery.

Your understanding of the requirements of § 173.185(b)(4) is correct. Lithium batteries installed in equipment may be transported unpackaged provided the equipment provides equivalent protection for the cells and batteries. When equipment containing lithium batteries is placed in an outer package § 173.185(b)(4)(ii) requires the equipment to be secured against movement and be packed so as to prevent accidental operation during transport.

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


Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.185(b)(4), 173.185(b)(4)(ii)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries