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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.



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