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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 #19-0016

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

Interpretation Response Details

Response Publish Date:

Company Name: Advance Auto Parts

Individual Name: Ryan Bodekor

Location State: NC Country: US

View the Interpretation Document

Response text:

August 30, 2019

Ryan L. Bodekor, ASHM, CDS
Director of Environmental, Health and Safety, North Division
Advance Auto Parts / General Parts Distribution
4729 Hargrove, Rd
Raleigh, NC 27604

Reference No. 19-0016

Dear Mr. Bodekor:

This letter is in response to your February 7, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. You describe a scenario in which a package consists of a pallet that contains electric storage batteries filled with acid and totes of other hazardous or non-hazardous materials. We have paraphrased and answered your questions as follows:

Q1. You ask whether the word "battery" is an acceptable package description, as required in § 172.202(a)(7).

A1. In this instance, the answer is no. In DOT-SP 16171, the pallet (containing the batteries and the totes of other non-hazardous materials) is the package which must be described on the shipping paper. The word "battery" does not accurately describe this package.

Q2. You ask whether "BATT" is an acceptable abbreviation.

A2. In this instance, the answer is no. See A1.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers