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Interpretation Response #20-0068

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

Interpretation Response Details

Response Publish Date:

Company Name: Zoll Medical Corporation

Individual Name: George Cole

Location State: WI Country: US

View the Interpretation Document

Response text:

April 6, 2021

George Cole
Logistics Manager
Zoll Medical Corporation
500 Burdick Parkway
Deerfield, WI  53531

Reference No. 20-0068

Dear Mr. Cole:

This letter is in response to your August 25, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) and the International Maritime Dangerous Goods (IMDG) Code applicable to the availability of test summaries for lithium cells and batteries. Specifically, you ask whether the practice of placing lithium battery test summary documents on your company's website complies with the "make available" requirements in accordance with the HMR, the ICAO Technical Instructions and the IMDG Code.

In your email, you state that your company's website contains all of the required lithium battery test summary documents, and that those documents are cross-referenced to the replacement lithium batteries for the products that your company sells. Additionally, you provide a link to your company's website to demonstrate that the test summary documents are available. Based on this information, it is the opinion of this Office that provided the lithium battery test summary documents are accessible, your company's practice of placing the lithium battery test summary documents on your public website meets the "make available" requirements of the HMR, the ICAO Technical Instructions and the IMDG Code.

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

Regulation Sections

Section Subject
171.22 Authorization and conditions for the use of international standards and regulations