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Interpretation Response #16-0045 ([Label master Services, Inc.] [Mr. Robert Richard])

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

Interpretation Response Details

Response Publish Date:

Company Name: Label master Services, Inc.

Individual Name: Mr. Robert Richard

Location State: IL Country: US

View the Interpretation Document

Response text:

July 26, 2016

Mr. Robert Richard
Vice President Regulatory Compliance
Labelmaster Services, Inc.
5724 N. Pulaski Rd.
Chicago, IL 60646

Ref. No.: 16-0045

Dear Mr. Richard:

This responds to your letter regarding provisions for lithium batteries transported by modes other than air when marked and labeled in accordance with Section IB of Packing Instruction (PI) 965 or 968 of the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI).

You ask whether a package that meets the provisions for the small cells and batteries in §173.185(c), and displays the Class 9 label and the lithium battery handling marking in accordance with Packing Instruction 965, Section IB for air transport, remain eligible to utilize marking and labeling exceptions applicable to modes other than air transport without removing the affixed Class 9 label and lithium battery handling marking. In addition, you suggest we include clarifying language in the HMR.

The answer is yes. The hazard communication requirements for lithium batteries prepared in accordance with Section IB (§ 173.185(c)(4)(vi) of the HMR) were added to ICAO TI in the 2013-2014 edition and are not new. The labels and markings required to be affixed to packages for transport by air in accordance with the ICAO TI (Class 9 and lithium battery handling markings) need not be removed or covered for subsequent transportation by other modes. Shipments prepared in accordance with Section IB remain eligible for the exceptions provided in § 173.185(c).

I hope 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)(4)(vi), 173.185(c)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
173.185 Lithium cells and batteries