Ingram — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Plpellne and Hazardous Materials Safety Administration 1200 New Jer•ey Avenue, SE Wathlngton, DC 20590 OCT J 1 2018 Tim Morgan Ingram 1451 All Points Court Plainfield, IN 46168 Reference No. 18-0084 Dear Mr. Morgan: This letter is in response to your June 4, 2018, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the lithium battery mark. Specifically, you ask if the lithium battery mark in § 173.185(c)(3) may be modified to include supplementary information in addition to the required UN identification number and phone number. The answer is no. The purpose of the marking is to indicate that the package contains lithium batteries in a clear and universal way. Changes to the marking 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 to that which is required in § 173.185(c)(3). I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, ~o<Y~~~- T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2January, lkeya CTR (PHMSA) From: INFOCNTR (PHMSA) Sent: To: Monday, June 04, 2018 9:52 AM Hazmat Interps Subject: FW: Request for Interpretation Good morning Alice and lkeya, Please see the below interp request. The requestor already spoke to Andrew here in the lnfoCenter, but has requested further interpretation. Regards, -Breanna From: Morgan, Timothy [mailto:Timothy.Morgan@lngrammicro.com) Sent: Friday, June 01, 2018 4:15 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request for Interpretation To Whom It May Concern, Can you please clarify whether the design for the lithium battery mark (§173.185(c)(3)) prohibits any information in addition to the required UN number and telephone number for additional information? My address is included below. Thank you, Tim Tim Morgan, CHMM Transportation HazMaUDangerous Goods Project Manager Commerce & Lifecycle Services· Office: 317.707.2496 I Mobile: 317.750.4444 IN. tHAM I s0eR;icEF s C Y C l• 1451 All Points Court Plainfield, IN 46168 1#