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Interpretation Response #16-0172 ([DGI Training] [Mr. Sean Kelly])

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

Interpretation Response Details

Response Publish Date:

Company Name: DGI Training

Individual Name: Mr. Sean Kelly

Location State: FL Country: US

View the Interpretation Document

Response text:

April 6, 2017

Mr. Sean Kelly
DGI Training
P.O. Box 16972
Fernandina Beach, FL 32035

Reference No. 16-0172

Dear Mr. Kelly:

This letter is in response to your October 23, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries. Specifically, you ask for confirmation of your understanding that button cell batteries installed in equipment can be transported as general cargo, regardless of the number of button cell batteries contained in the equipment, provided the total weight of button cell batteries in each package does not exceed 5 kilograms (kg).

You offer the following as an example of a package you believe should be accepted and transported as general cargo:

  • A package contains 100 pieces of equipment—each piece of equipment contains 6 lithium button cell batteries—for a total of 600 button cell batteries in a package;
  • Each button cell battery contains less than 1 gram (g) of lithium; and
  • Each package contains not more than 5 kg of button cell batteries.

Your understanding is correct. In accordance with § 173.185(c), a package containing lithium metal cells or batteries (not exceeding 1 g for a lithium metal cell or 2 g for a lithium metal battery) contained in equipment in quantities less than 5 kg net weight per package is excepted from the requirement to mark the outer package to indicate it is forbidden aboard passenger aircraft. In addition, § 173.185(c)(3) excepts button cell batteries installed in equipment (including circuit boards), or equipment installed with four lithium cells or two lithium batteries or less, from the hazard communication requirements prescribed in that section, including the marking and documentation requirements prescribed in § 173.185(c)(3)(i), (ii), and (iii). Please note the four lithium cell/two battery limit exception in § 173.185(c)(3) does not apply to button cell batteries installed in equipment.

I hope this information is helpful. Please contact us if we can be of further assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.185(c), 173.185(c)(3), 173.185(c)(3)(i), (ii), and (iii)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries