Interpretation Response #15-0057 ([Clean Pack Training and Development] [Mr. Kevin S. Young])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Clean Pack Training and Development
Individual Name: Mr. Kevin S. Young
Location State: MA Country: US
View the Interpretation Document
Response text:
April 15, 2015
Mr. Kevin S. Young
Clean Pack Training and Development
Clean Harbors
42 Longwater Drive
Norwell, MA 02061-9149
Ref. No.: 15-0057
Dear Mr. Young:
This responds to your March 20, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the transport of dry batteries. The exception for used or spent dry batteries prescribed § 172.102, Special Provision 130, paragraph (d), requires that batteries utilizing different chemistries as well as dry batteries with a marked rating greater than 9-volt may not be combined with used or spent batteries in the same package. You ask if the term "package" applies to the inner bags containing the batteries or the outer package being offered for transport.
The term "package" refers to the completed package being offered for transport. As defined in § 171.8, a "package" or "outside package" means a packaging plus its contents. Therefore, in this scenario, batteries utilizing different chemistries or with a marked rating greater than 9-volt would need to be packed in separate packages.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
172.102, 171.8
Regulation Sections
| Section | Subject |
|---|---|
| 171.8 | Definitions and abbreviations |
| 172.102 | Special provisions |