Interpretation Response #10-0021 ([Ohio State Highway Patrol] [Major Christopher K. Minter])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Ohio State Highway Patrol
Individual Name: Major Christopher K. Minter
Location State: OH Country: US
View the Interpretation Document
Response text:
March 22, 2011
Major Christopher K. Minter
Commander, Office of Field Operations
Ohio State Highway Patrol
1970 West Broad Street
P.O. Box 182074
Columbus, OH 43218-2081
Ref. No.: 10-0021
Dear Major Minter:
This is in response to your January 26, 2010 letter requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to battery shipments. According to your letter, the batteries in question are secured to a pallet with stretch-wrap. The batteries are stacked on top of each other in rows, and cardboard is placed between each tier to prevent short circuits. Specifically, you ask about appropriate methods for protecting batteries against short circuits during transportation.
Shipments of electric storage batteries are excepted from the HMR if the provisions found in
§ 173.159(e)(1)-(4) are met. In accordance with § 173.159(e)(2), wet electric storage batteries must be loaded or braced so as to prevent damage and short circuits in transit. There are a number of methods that will satisfy the performance standard, including the use of non-conductive caps that entirely cover the terminals; utilizing cardboard, paper, wood, or similar materials to separate the batteries and cover the terminals; the use of friction mats or wooden pallets to secure the batteries against movement; or a combination of measures that will prevent damage and short circuits in transit. Batteries may be stacked provided they are secured in a manner that prevents damage and short circuits in transit.
I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
173.159
Regulation Sections
| Section | Subject |
|---|---|
| 173.159 | Batteries, wet |