Interpretation Response #05-0017 ([Waste Technology Services Inc] [Mr. T.L. Nebrich])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Waste Technology Services Inc
Individual Name: Mr. T.L. Nebrich
Location State: NY Country: US
View the Interpretation Document
Response text:
Feb 8, 2005
Mr. T.L. Nebrich Reference No. 05-0017
Technical Director
Waste Technology Services Inc.
435 North 2nd Street
Lewiston, NY 1409:2
Dear Mr. Nebrich:
This is in response to your January 11, 2005 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17l-180) to the packaging of batteries. Section 173.159(c) (1) authorizes a packaging that would consist of batteries firmly secured to a pallet. Specifically, you ask if this packaging should be treated as either a bulk or non- bulk package and how the package should be marked, labeled, and/or placarded.
For the purposes of marking, labeling, and placarding, a shipment of electric storage batteries secured to a pallet in accordance with § 173.159(c) (1) is considered to be a single non-bulk package. The completed package must be marked in accordance with § 172.301 and labeled in accordance with § 172.400. The palletized batteries should be marked and labeled as a non-bulk package even if the completed package weighs more than 400 kg (882 pounds)
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Hattie Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
171.8, 173.159(c)(1)
Regulation Sections
| Section | Subject |
|---|---|
| 171.8 | Definitions and abbreviations |
| 173.159 | Batteries, wet |