Interpretation Response #11-0125 ([Mr. Hank Sheller])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Hank Sheller
Location State: NY Country: US
View the Interpretation Document
Response text:
June 16, 2011
Mr. Hank Sheller
9707 63rd Rd, #11D
Rego Park, NY 11374
Reference No. 11-0125
Dear Mr. Sheller:
This responds to your May 13, 2011 letter requesting clarification of the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for the shipment of a 9-volt alkaline battery packaged as part of a kit. The battery is shrink-wrapped and then placed in the kit adjacent to other items. You request confirmation that the kit described in your letter may be transported to and within the United States by all modes of transportation.
Dry batteries (i.e., "Batteries, dry, sealed, n.o.s" as listed in the §172.101 Hazardous Materials Table) such as the alkaline battery illustrated in your letter are subject only to the requirements outlined in § 172.102, Special provision 130 of the HMR. The requirements include: (1) incident reporting; and (2) preparation and packaging of the battery to prevent a dangerous evolution of heat, short circuit, and damage to terminal(s). Shrink-wrapping the battery is an acceptable method of preparing the battery for shipment. We also suggest placing the battery in the kit so that it is separated from conductive material contained in the package (e.g., the allen wrenches). If the battery is also packaged in a manner to prevent damage to the terminal, then we consider the kit acceptable for hazardous material transportation without further requirements. We recommend you review § 172.102, Special Provision 130 to familiarize yourself with the complete requirements and we have enclosed a copy of a guide for shipping batteries safely, Shipping Batteries Safely by Air; What You Need to Know to aid your understanding of shipping all battery types including alkaline.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Ben Supko
Chief, Standards Development Branch
Standards and Rulemaking Division
Enclosure: Shipping Batteries Safely by Air; What You Need to Know
172.101, 172.102 SP 102
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |