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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.


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