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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 #13-0186 ([UTi] [Ms. Kathryn Singer])

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

Interpretation Response Details

Response Publish Date:

Company Name: UTi

Individual Name: Ms. Kathryn Singer

Location State: MI Country: US

View the Interpretation Document

Response text:

January 22, 2013

Mr. Kathryn Singer
4460 44th Street SE, Suite G
Grand Rapids, MI 49512

Ref. No. 13-0186

Dear Ms. Singer:

This responds to your September 6, 2013 email regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of a motor vehicle lift system powered by a wet acid battery.  In your letter, you indicate that the battery is installed in the system when shipped and that the system is shipped upright with protective material around the system.  You also provide a safety data sheet for the battery, images of the system, and a web link to a video showing the installed battery.  No other hazardous material is contained in the system.  Thus, your understanding is that the system as described and shown would not be subject to the HMR when you transport it by highway, rail and vessel.

In accordance with § 173.22, it is the shipper’s responsibility to ensure compliance with the requirements of the HMR.  The system you describe is considered battery-powered equipment, which is eligible for exception from the HMR under § 173.220.  In accordance with
§ 173.220(c), a wet battery must be securely installed and fastened in an upright position.  The battery must also be protected against a dangerous evolution of heat, short circuit, damage to terminals, and leakage.  Battery-powered equipment meeting these conditions, containing no other hazardous material and transported by highway, rail or vessel is not subject to the HMR (except for the forbidden conditions of § 173.21 applicable to batteries).  Based on the information you provided, it is the opinion of this Office that the motor vehicle lift system would not be subject to the HMR.  

I hope this information is helpful.  If you have further questions, please contact this office.


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

173.22, 173.220

Regulation Sections

Section Subject
173.21 Forbidden materials and packages
173.22 Shipper's responsibility
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery