Interpretation Response #02-0040 ([GS Battery (U.S.A.) Inc.] [Greg DePies])

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

Interpretation Response Details

Response Publish Date: 02/22/2002

Company Name: GS Battery (U.S.A.) Inc.

Individual Name: Greg DePies

Location State: CA Country: US

View the Interpretation Document

Response text:

February 22, 2002

Mr. Greg DePies                    Reference No. 02-0040
GS Battery (U.S.A.) Inc.
7576 Trade street, Suite B
San Diego, CA 92121

Dear Mr. DePies:

This is in response to Your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) applicable to the transportation of nonspillable batteries. Specifically, you want to confirm that your company is in compliance with the provisions of § 173.159(d)(1), which states that "the battery must be protected against short circuits and securely packaged."

You state that the batteries are loaded on heavy duty pallets, separated by cardboard dividers, the battery terminals are capped, and the rows separated by bubblewrap and cardboard.  The pallet is banded horizontally and vertically and then wrapped in 5 mil thick tarp.  In addition to the description, you also submitted several photographs showing batteries in various stages of preparation for shipment.  Based on the information provided, it is the opinion of this office that the batteries are "securely packaged."

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.

Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.159(d)(1)

Regulation Sections