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Interpretation Response #16-0102 ([Amerflight] [Mr. Matt Payne])

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

Interpretation Response Details

Response Publish Date:

Company Name: Amerflight

Individual Name: Mr. Matt Payne

Location State: TX Country: US

View the Interpretation Document

Response text:

January 11, 2017

Mr. Matt Payne
Hazmat Program and Compliance Manager
1515 W. 20th St.
DFW Airport, TX 75261

Reference No. 16-0102

Dear Mr. Payne,

This responds to your June 10, 2016 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) applicable to the transport of lithium batteries. Specifically you ask if lithium batteries that meet the requirements of 173.185(c) and are excepted from shipping paper requirements are also excepted from the pilot notification requirements of § 175.33.

Lithium batteries that comply with the size, packaging, hazard communication, air transportation, and marking exceptions prescribed for smaller lithium cells and batteries in § 173.185(c) are excepted from the requirements in 49 CFR Part 172, subparts C (Shipping Papers), D (Marking), E (Labeling), F (Placarding), G (Emergency Response Information), and H (Training), and the UN performance packaging requirements prescribed in § 173.185(b)(3)(ii) and (b)(4).

A consignment of lithium batteries that is excepted from the shipping paper requirements in subpart C of part 172 is not subject to the shipping paper and pilot notification requirements prescribed in § 175.33.

I hope this satisfies your inquiry. Please feel free to contact us if we can be of further assistance.



Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.185(c), 175.33, 173.185(b)(3)(ii) and (b)(4)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries
175.33 Shipping paper and notification of pilot-in-command