Interpretation Response #07-0138 ([HAZ-MAT Transportation Services] [Mr. Jack Peters])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HAZ-MAT Transportation Services
Individual Name: Mr. Jack Peters
Location State: WA Country: US
View the Interpretation Document
Response text:
July 20, 2007
Mr. Jack Peters Reference No. 07-0138
HAZ-MAT Transportation Services
P.O. Box 69206
Seattle, WA 98168
Dear Mr. Peters:
This is in response to your July 9, 2007 letter regarding packaging requirements for batteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if it is permissible to transport "Batteries, wet, filled with acid, 8, UN 2794, PG III," "Battery fluid, acid, 8, UN 2796, PG II," and batteries that have yet to be filled with acid on the same palette.
The answer is yes. Wet electric storage batteries that are packaged in accordance with § 173.1 59(c)(1) may be placed inside a larger package or affixed to a palette that also contains other compatible hazardous and non-hazardous materials. This shipping configuration is referred to as an overpack, as defined in § 171.8. It requires the battery to be packaged in accordance with § 173.l59(c)(1), the battery acid in accordance with § 173.159(g), and the overpack in accordance with the requirements specified in § 173.25. The overpack must be marked and labeled for each hazardous material contained therein unless markings and labels representative of each hazardous material in the overpack are visible.
You should also be aware that when packaged and overpacked as described in your letter, the exception in § 173.159(e) does not apply to electric storage batteries. Electric storage batteries containing electrolyte or corrosive battery fluid are excepted from the HMR when transported in accordance with the provisions specified in § 173.159(e). The condition specified in § 73.159(e)(1) states that no other hazardous materials may be transported on the same vehicle. Therefore, with the exception of the batteries, no hazardous materials, including corrosive battery fluid, may be transported on the vehicle.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.159(e), 173.25
Regulation Sections
Section | Subject |
---|---|
173.159 | Batteries, wet |
173.25 | Authorized packagings and overpacks |