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Interpretation Response #15-0171 ([AECOM] [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: AECOM

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

August 11, 2016

Mr. Andrew N. Romach
Regulatory Compliance Manager
1600 Perimeter Park Drive
Morrisville, NC 27560

Ref. No.: 15-0171

Dear Mr. Romach:

This is in response to your letter dated August 3, 2015 and subsequent phone call with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to lithium battery provisions in § 173.185.   You state that you have a single lithium metal battery contained in equipment.  This single lithium metal battery contained in equipment has a lithium content of not more than 2 grams and the lithium metal content does not exceed 5 kg net weight.  The equipment is then placed in an outer product box that meets the criteria for a strong outer packaging and all of the applicable packaging provisions in § 173.185(c).  You further state the product box would be consolidated with other product boxes and placed into one larger box.  You ask for confirmation that the product box as well as the overpack would require no hazard communication marks or labels based on the scenario you have provided.

Your understanding is correct.  For the packages and overpack you describe there is no requirement to mark or label the outer package or overpack.  The package is not required to display the markings specified in §§ 173.185(c)(1)(iii) and 173.185(c)(3).  The package would also be excepted from labeling per § 173.185(c).  In accordance with § 173.25(a)(4), the overpack marking would not be required, as specification packagings are not required.    

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, 173.185(c), 173.185(c)(1)(iii),  173.185(c)(3), 173.25(a)(4)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
173.185 Lithium cells and batteries
173.185 Lithium cells and batteries
173.185 Lithium cells and batteries
173.25 Authorized packagings and overpacks