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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 #03-0219 ([Department of the Navy] [Mr. Daniel J. Burke])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Navy

Individual Name: Mr. Daniel J. Burke

Location State: RI Country: US

View the Interpretation Document

Response text:

Sep 25, 2003


Mr. Daniel J. Burke               Reference No.03-0219
Acting Head, Environmental, Safety
and Security Department
Depart of the Navy
Naval Undersea Warfare Center Division
1176 Howell Street
Newport RI 02841-1708

Dear Mr. Burke:

This is in responds to your letter and subsequent telephone conversation with Gigi Corbin of my staff, requesting clarification of § 173.159(c)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Partsl7l-180). Specifically you asked whether you may ship Batteries, wet, filled with alkali, 8, UN 2795, PG III under the provisions of § 173.159(c)(1) via rail, highway or vessel.

According to your letter, you are shipping 200 batteries in the original manufacturer's crate or
in similar newly constructed crates.  The batteries will be packed and secured in a manner to prevent any of the battery terminals from supporting the superimposed weight.  In addition, the crates will be secured to pallets or skids with banding.  The estimated weight of the batteries, pallet or skid, and crate is 1100 lbs.  Section 173.159(c)(1) allows electric storage batteries protected against short circuits and firmly secured to skids or pallets capable of withstanding the shocks normally incident to transportation to be transported by rail, highway, or water.  The height of the completed unit must not exceed 1 ½ times the width of the skid or pallet.  The unit must be capable of withstanding, without damage, a superimposed weight equal to two times the weight of the unit or, if the weight of the unit exceeds 907 kg (2000 pounds), a superimposed weight of 1814 kg (4000 pounds).  Battery terminals must not be relied upon to support any part of the superimposed weight.  Provided all provisions in § 173.159(c)(1) are met, your understanding is correct.

I hope this information is helpffil.  Please contact us if you require additional assistance



Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.159 Batteries, wet