USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #11-0125 ([Mr. Hank Sheller])

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. Hank Sheller

Location State: NY Country: US

View the Interpretation Document

Response text:

June 16, 2011



Mr. Hank Sheller

9707 63rd Rd, #11D

Rego Park, NY 11374

Reference No. 11-0125

Dear Mr. Sheller:

This responds to your May 13, 2011 letter requesting clarification of the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for the shipment of a 9-volt alkaline battery packaged as part of a kit. The battery is shrink-wrapped and then placed in the kit adjacent to other items. You request confirmation that the kit described in your letter may be transported to and within the United States by all modes of transportation.

Dry batteries (i.e., "Batteries, dry, sealed, n.o.s" as listed in the §172.101 Hazardous Materials Table) such as the alkaline battery illustrated in your letter are subject only to the requirements outlined in § 172.102, Special provision 130 of the HMR. The requirements include: (1) incident reporting; and (2) preparation and packaging of the battery to prevent a dangerous evolution of heat, short circuit, and damage to terminal(s). Shrink-wrapping the battery is an acceptable method of preparing the battery for shipment. We also suggest placing the battery in the kit so that it is separated from conductive material contained in the package (e.g., the allen wrenches). If the battery is also packaged in a manner to prevent damage to the terminal, then we consider the kit acceptable for hazardous material transportation without further requirements. We recommend you review § 172.102, Special Provision 130 to familiarize yourself with the complete requirements and we have enclosed a copy of a guide for shipping batteries safely, Shipping Batteries Safely by Air; What You Need to Know to aid your understanding of shipping all battery types including alkaline.

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


Ben Supko

Chief, Standards Development Branch

Standards and Rulemaking Division

Enclosure: Shipping Batteries Safely by Air; What You Need to Know

172.101, 172.102 SP 102

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table