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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 #08-0202 ([Mr. Carl Severn])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Carl Severn

Location State: CO Country: US

View the Interpretation Document

Response text:

October 14, 2008




Mr. Carl Severn

12596 W Bayaud Avenue, Suite 210

Lakewood, Colorado 80228

Ref. No. 08-0202

Dear Mr. Severn:

This is in response to August 5, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provide six common battery types and the proper shipping description that you believe is appropriate for each. You ask that we confirm the proper shipping descriptions for each of the six battery types. The battery type and your description for each are summarized as follows:

1. Nickel-Cadmium batteries (dry, typically for appliances, toys, and cordless phones).

Proper shipping description: Battery, dry, not subject to the requirements of this subchapter.

2. Nickel-Cadmium batteries (wet) Proper shipping description: Batteries, wet, filled with alkali, 8, UN3028, III

3. Alkaline Batteries (common AA, D, and C cell batteries) Proper shipping description: Battery, dry, not subject to the requirements of this subchapter

4. Lithium-manganese dioxide batteries (found in phones and digital cameras)

Proper shipping description: Lithium battery, 9, UN3090, II

5. Lithium ion button batteries (typically for watches and calculators)

Proper shipping description: Lithium battery, 9, UN3090, II

6. Silver oxide batteries (common in watches) Proper shipping description: Battery, dry, not

subject to the requirements of the subchapter

It is the shipper"s responsibility to properly class and describe a hazardous material in accordance with the HMR (see § 173.22, shipper responsibility). This office does not perform that function. However, it is the opinion of this Office that the proper shipping descriptions you have provided for each battery type are appropriate. Please note that batteries described as "Batteries, dry, not subject to the requirements of this subchapter" must be securely packaged and offered for transportation in a manner that prevents the dangerous evolution of heat (for example, by effective insulation of exposed terminals) and protects against short circuits (see § 172.102, special provision 130).

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

Sincerely,

Susan Gorsky,

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.22,172.101, 173.185

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility