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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #19-0003

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

Interpretation Response Details

Response Publish Date:

Company Name: Cabela's

Individual Name: Dale Kettler

Location State: NE Country: US

View the Interpretation Document

Response text:

May 2, 2019

Dale Kettler
Senior Manager
2 Cabela Dr.
Sidney, NE 69160

Reference No. 19-0003

Dear Mr. Kettler:

This letter is in response to your December 19, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to products not subject to the shipping paper requirements. Specifically, you ask how lithium batteries shipped under the exceptions in § 173.185(c) should be described on a bill of lading to meet shipping paper requirements in part 172 of the HMR?

As stated in § 173.185(c), a package containing lithium cells or batteries, or lithium cells or batteries packed with, or contained in, equipment, meeting the conditions prescribed therein, are excepted from the requirements of subparts C through H of part 172 of the HMR. This includes the requirement to provide a hazardous materials shipping paper with a hazardous materials description specified in § 172.202. Therefore, PHMSA does not require a specified format on a bill of lading to describe such items. Similarly, as stated in § 172.200(b)(3), a limited quantity is not subject to shipping paper requirements unless the material is offered for transportation by aircraft or vessel.

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


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

173.185(c), 172.202, 172.200(b)(3)

Regulation Sections

Section Subject
172.200 Applicability
172.202 Description of hazardous material on shipping papers
173.185 Lithium cells and batteries