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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 #98-0544 ([nternational Air Transportation] [Mr. Gary Dixon])

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

Interpretation Response Details

Response Publish Date:

Company Name: nternational Air Transportation

Individual Name: Mr. Gary Dixon

Location State: TX Country: US

View the Interpretation Document

Response text:

JUN 11, 1998


Mr. Gary Dixon
International Air Transportation
Panal Pina
18600 Lee Road
Houston, TX 77338

Dear Mr. Dixon:

This is in response to your inquiry of May 27, 1998 concerning the limitation for lithium batteries and cells packed with equipment as specified in the Hazardous Materials Regulatior (HMR; 49 CFR Parts 171-181). You specifically asked whether the 5 kilogram limit in § 173.185(g)(2) applies to each item of equipment and whether multiple items of equipment may be contained in a single package.

In response to your questions, it is our opinion that the 5 kilogram limit in § 173. 185(g)(2) specifically applies to each item of equipment and that more than one item of equipment may be placed in a package. For example, you may have four items of equipment in a given package each packaged with a lithium battery or cells with a mass of not more than 5 kilograms. In this scenario you could have up to 20 kilograms of cells or batteries as long as no single battery or cell exceeds 5 kilograms in mass. As specified in § 173.185(g)(2), the cells and batteries must be packed in inner packagings in such a manner as to effectively prevent movement and short circuits. In addition to the limits in § 173.185, the § 172.101 Hazardous Materials Table specifies quantity limits on packages containing lithium batteries of 5kg for passenger aircraft and 35kg gross for cargo aircraft only. Therefore, for passenger: aircraft, each package containing lithium batteries packed with equipment is limited to a maximum net mass of 5kg. For cargo aircraft, the maximum quantity per package is 35kg gross mass (see the "Lithium battery" entry in the § 172.101 Hazardous Materials Table).

For your information, the HMR currently does not include a specific entry for lithium batteries packed with equipment consistent with the International Civil Aviation Organization's Technical Instructions on the Safe Transport of Dangerous Goods by Air (ICAD TI). Shipments prepared in accordance with the HMR must use the "Lithium batter: entry, UN 090. If the shipment is prepared and certified in accordance with the lCAO TI then you may use the description "Lithium batteries packed with equipment", UN 3091 and packing instruction 918. This is permitted by HMR; § 171.11. RSP A is considering whether to incorporate the entry "Lithium batteries packed with equipment", UN 3091 in a future rulemaking project.

I hope this information is helpful.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.185 Lithium cells and batteries