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Interpretation Response #19-0083

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

Interpretation Response Details

Response Publish Date:

Company Name: Currie Associates

Individual Name: L’Gena Shaffer

Location State: NY Country: US

View the Interpretation Document

Response text:

May 22, 2020

L'Gena Shaffer
Senior Technical Consultant
Currie Associates
10 Hunter Brook Lane
Queensbury, NY 12804

Reference No. 19-0083

Dear Ms. Shaffer:

This letter is in response to your June 19, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the lithium battery mark. Specifically, you ask whether the lithium battery mark provided in § 173.185(c)(3) may be modified to include supplementary information in addition to the required UN identification number and telephone number. You provide three examples of the modifications to the lithium battery mark and ask whether they meet the requirements of the HMR.

Your examples are paraphrased and responded to as follows:

Q1. Example 1: You ask whether the lithium battery mark may include a United States Postal Service (USPS) "Surface Mail Only, Lithium-ion Batteries- Forbidden for Transportation Aboard Passenger Aircraft" mark in addition to the UN number and telephone number required in § 173.185(c)(3)(i).

A1. The answer is no. The purpose of the marking is to indicate that the package contains lithium batteries in a clear and universal way. Additional information not relevant to the components of the mark could diminish the effectiveness of the lithium battery mark and cause confusion in transportation. Therefore, the lithium battery mark may not be modified to include additional information not relevant to the components of the mark specified in § 173.185(c)(3)(i).

Q2. Example 2: You ask whether additional text may be added outside of the required red hatchings on the lithium battery mark.

A2. The answer is yes. It is the opinion of this Office that additional information outside of the required red hatching in the example provided would not diminish the effectiveness of the lithium battery mark.

Q3. Example 3: You ask whether the lithium battery mark may include a barcode in addition to the UN number and telephone number required in § 173.185(c)(3)(i).

A3. The answer is no. See answer A1.

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

Sincerely,

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

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

Regulation Sections

Section Subject
173.185 Lithium cells and batteries