Interpretation Response #07-0223 ([U.S. Battery Manufacturing Company] [Mr. Terry Campbell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: U.S. Battery Manufacturing Company
Individual Name: Mr. Terry Campbell
Location State: CA Country: US
View the Interpretation Document
Response text:
March 18, 2008
Mr. Terry Campbell
U.S. Battery Manufacturing Company
1675 Sampson Avenue
Corona, CA 92879
Ref. No.: 07-0223
Dear Mr. Campbell:
This is in response to your November 13, 2007 letter regarding stowage of batteries transported by vessel under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the requirement specified in § 176.76(a)(6) is satisfied by the use of a level 1 dunnage air bag.
In accordance with § 176.76(a)(6), any slack spaces between packages must be filled with dunnage. The HMR do not specify the type of dunnage required nor, in the event a dunnage air bag is used, do the HMR specify the type of air bag. Any suitable air bags may be used as dunnage. Under § 176.76(a)(2), all packages in a transport vehicle or freight container must be secured to prevent shifting. If it is your experience that a level 1 air bag will satisfy the requirements in § 176.76 paragraphs (a)(2) and (6), you may use them to provide dunnage.
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
176.76(a)(6)