Interpretation Response #25-0051
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Iowa State Patrol Iowa Department of Public Safety
Individual Name: Glenn Goode
Location State: IA Country: US
View the Interpretation Document
Response text:
Sergeant Glenn Goode
Iowa State Patrol
Iowa Department of Public Safety
215 East 7th Street
Des Moines, IA 50319
Reference No. 25-0051
Dear Sgt. Goode:
This letter is in response to your April 7, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazmat registration for lithium batteries that comprise a battery energy storage system (BESS). You describe a scenario involving lithium batteries, installed in a Cargo Transport Unit (CTU). The bill of lading enclosed with your letter indicates the dimensions of the cargo transport unit of 19.11 feet long, 8.08 feet wide, and 9.07 feet tall (approximately 1,400 cubic feet), weighing approximately 77,000 pounds. You ask if this cargo transport unit would be considered a bulk packaging under the definition in § 171.8.
Yes. As defined in § 171.8, bulk packaging is defined as a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. Because the batteries described in your letter are housed within a single container, and wired together as a single unit, rather than being separated into individual inner packages, the container is considered a bulk packaging. In addition, registration is required under § 107.601(a)(4) for any shipment of hazardous materials in a bulk packaging (see § 171.8 of this chapter) that has a capacity of at least 13.24 cubic meters (468 cubic feet) for solids.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review & Reinvention
Standards and Rulemaking Division
171.8 107.601(a)(4)
Regulation Sections
| Section | Subject |
|---|---|
| 107.601 | Applicability |
| 171.8 | Definitions and abbreviations |