Interpretation Response #12-0180 ([Concorde Battery] [Mr. Steve Delmar])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Concorde Battery
Individual Name: Mr. Steve Delmar
Location State: CA Country: US
View the Interpretation Document
Response text:
October 25, 2012
Mr. Steve Delmar
Director of Environmental Health and Safety
Concorde Battery
2009 San Bernadino Rd
West Covina, CA 91790
Reference No.: 12-0180
Dear Mr. Delmar:
This is in response to your August 12, 2012 letter requesting clarification on marking requirements for non-spillable batteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You present a scenario where non-spillable batteries are marked "NONSPILLABLE" or "NONSPILLABLE BATTERY" both on the battery itself and its outer packaging in accordance with the packaging exception provided in § 173.159a(c)(2). The batteries are then palletized, and in the process of creating this palletized load the "NONSPILLABLE" marking is covered up with corrugated sheeting and/or stretch wrap. You ask if the outer pallet wrapping material must also be marked "NONSPILLABLE."
The answer is no. In the scenario you describe, your properly marked and packaged non-spillable batteries are then consolidated on a skid using corrugated sheeting and/or stretch wrap. There is no requirement in the HMR to carry the "NONSPILLABLE" marking over to the outside of the corrugated sheeting or stretch wrap.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
173.159
Regulation Sections
| Section | Subject |
|---|---|
| 173.159 | Batteries, wet |