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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 #10-0105 ([Bergeson & Campbell, P.C.] [Mr. Christopher R. Bryant])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bergeson & Campbell, P.C.

Individual Name: Mr. Christopher R. Bryant

Location State: DC Country: US

View the Interpretation Document

Response text:

June 29, 2010




Mr. Christopher R. Bryant

Bergeson & Campbell, P.C.

1203 Nineteenth Street, NW

Suite 300

Washington, DC 20036-2401

Ref. No. 10-0105

Dear Mr. Bryant:

This responds to your letter requesting clarification of the exceptions provided for lead acid batteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the condition specified in § 173.159(e)(4) applies to only one shipper as stated in our November 4, 2009 response (Ref. No. 10-0025) and whether that response supersedes our July 22, 2009 response on the same subject.

The answer to both of your questions is yes. The exceptions provided in § 173.159(e) only apply to a single shipper of batteries per transport vehicle and not to multiple shippers (so-called "milk runs"). Additionally, we have removed the July 22, 2009 letter you reference from our interpretation database to avoid any confusion regarding this issue in the future.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.159 Batteries, wet