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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 #19-0028

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

Interpretation Response Details

Response Publish Date:

Company Name: J.J. Keller and Associates, Inc.

Individual Name: Thomas J. Ziebell

Location State: WI Country: US

View the Interpretation Document

Response text:

August 23, 2019

Thomas J. Ziebell
Sr. Editor – Hazardous Materials Trans.
J.J. Keller and Associates, Inc.
P.O. Box 368
Neenah, WI  54957

Reference No. 19-0028

Dear Mr. Ziebell:

This letter is in response to your March 12, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking requirements for lithium cells and batteries. Specifically, you ask whether more than one telephone number may be provided on the mark required by § 173.185(c)(3). You describe a scenario where one telephone number is provided for the domestic transportation portion of a trip and a different telephone number for the international transportation portion.

The answer is yes. Section 173.185(c)(3)(i)(C) does not prohibit including multiple telephone numbers provided each number reaches a person that can provide additional information on the contents of the package. Furthermore, identifying that one number is for domestic purposes and the other number is for international purposes is also not prohibited.

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


Dirk Der Kinderen
Chief, Standards Development
Standards and Rulemaking Division

173.185(c)(3), 173.185(c)(3)(i)(C)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries