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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 #08-0174 ([YRCW- North American Transportation] [Mr. Robert A. Maberry III Sr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: YRCW- North American Transportation

Individual Name: Mr. Robert A. Maberry III Sr.

Location State: KS Country: US

View the Interpretation Document

Response text:

January 16, 2009






Mr. Robert A. Maberry III

Sr. Administrator-Chemical Transportation

Hazardous Materials Dept.

YRCW- North American Transportation

10990 Roe Avenue

Mail Stop A605

Overland Park, KS 66211

Ref. No. 08-0174

Dear Mr. Maberry:

This responds to your letter requesting assistance in determining the description required for an electric storage battery on a shipping paper under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask what "number and type of packages" required under § 172.202(a)(7) should be indicated on a shipping paper for a 650-lb electric storage battery containing acid (UN2794) that is secured to a skid conforming to the non-specification packagings authorized for batteries under § 173.159(c)(1). More specifically, you ask whether the description "1 skid, Battery, wet, filled with acid, 8, UN2794, III, 650 pounds" is acceptable or if "1 Battery, Battery, wet, filled with acid, 8, UN2794, III, 650 pounds" would be a more appropriate description.

Because § 173.159(c)(1) requires the battery to be secured to a skid without any further packaging, the description "1 skid, Battery, wet, filled with acid, 8, UN2794, III, 650 pounds" is more appropriate.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

 

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of hazardous Materials Standards

172.202(a)(7), 173.159(c)(1)

Regulation Sections

Section Subject
173.159 Batteries, wet