Interpretation Response #01-0145 ([ShipMate, Inc.] [Mr. Steven Hunt])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ShipMate, Inc.
Individual Name: Mr. Steven Hunt
Location State: CA Country: US
View the Interpretation Document
Response text:
JUL 18, 2001
Mr. Steven Hunt Ref. No. 01-0145
President
ShipMate, Inc.
18436 Hawthorne Blvd.,
Suite 201
Torrance, CA 90504
Dear Mr. Hunt:
This responds to your May 29, 2001 letter requesting clarification of the requirements for the shipment of a battery electrolyte refill unit under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code. Specifically, you ask whether the battery electrolyte refill unit may be shipped under the limited quantity aprovisions in § 173.154(b)(1) of the HMR and Amendment 30-00 of the IMDG Code.
According to your letter and enclosed sketch, the battery electrolyte refill unit consists of a single molded plastic device having two independent reservoirs of equal volumes not exceeding 465 ml each. The two reservoirs each contain three "cells," having a volume of 155 ml each, that are in communication with one another. The single molded plastic device is hermetically sealed with a plastic bag and then placed into a UN 4G box. You ask whether each independent reservoir is considered to be an "inner packaging" as defined in § 171.8 of the HMR.
The answer is yes. Consistent with § ·171.8, each independent reservoir of the refill unit is a separate inner packaging. Thus, a battery electrolyte refill unit as described in your letter may be shipped as a limited quantity under Amendment 30-00 of the IMDG Code and § J73.l54(b)(1) of the HMR. Amendment 30-00 of the IMDG Code limits the maximum quantity of each receptacle to 500 ml; the limited quantity provisions in § 173.154(b)(1) of the HMR authorize a maximum of 1 liter in each inner packaging.
I hope this answers your inquiry.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.154(b)
Regulation Sections
| Section | Subject |
|---|---|
| 173.154 | Exceptions for Class 8 (corrosive materials) |