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.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.159
Regulation Sections
| Section | Subject |
|---|---|
| 173.159 | Batteries, wet |