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Interpretation Response #17-0127

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

Interpretation Response Details

Response Publish Date:

Company Name: Sandia National Laboratories

Individual Name: Shawn Colborg

Location State: NM Country: US

View the Interpretation Document

Response text:

January 23, 2018

Shawn Colborg
Sandia National Laboratories
1515 Eubank SE
Albuquerque, NM 87123

Reference No. 17-0127

Dear Mr. Colborg:

This letter is in response to your November 15, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries. You explain that your company produces a non-UN tested prototype lithium battery contained in equipment. While the lithium battery weighs less than 12 kg (26.5 pounds), the equipment in which the lithium battery will be contained weighs more than 12 kg (26.5 pounds). Specifically, you ask if the prototype lithium battery contained in equipment meets the requirements of § 173.185(e)(4), which allow shipment in a strong outer packaging, or if the completed package must meet the requirements of § 173.185(e)(3).

Based on the information you provided, you would not be permitted to pack the equipment in strong outer packagings, in protective enclosures, or on pallets or other handling devices and must instead comply with UN performance packaging requirements. The 12kg (26.5 pounds) or more exception in § 173.185(e)(4) applies to the battery only and not the combined weight of the battery and the equipment.

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


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

173.185(e)(4), 173.185(e)(3)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries