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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 #20-0021

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

Interpretation Response Details

Response Publish Date:

Company Name: Scopelitis, Garvin, Light, Hanson & Feary, P.C.

Individual Name: Timothy W Wiseman

Location State: IN Country: US

View the Interpretation Document

Response text:

August 14, 2020

Timothy W Wiseman
Scopelitis, Garvin, Light, Hanson & Feary, P.C.
10 West Market Street, Suite 1400
Indianapolis, IN  46204

Reference No. 20-0021

Dear Mr. Wiseman:

This letter is in response to your March 4, 2020, email and subsequent phone conversations with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of UN 2794, Batteries, wet, filled with acid, electric storage, 8. In your letter, you describe a scenario where (1) the battery "cells" have independent enclosures and terminals that are connected to other "cells" with cable leads, (2) no individual "cell" exceeds the 882-pound net mass or 119-gallon volumetric capacity threshold, and (3) the "cells" are contained within an intermediate steel containment. Specifically, you ask whether the mass and volumetric capacities of batteries should be assessed on an individual "cell" basis or as a combined unit when determining whether a packaging meets the definition of a "bulk" or "non-bulk" packaging in § 171.8.

Based on the information you provided in your scenario, the mass and capacity of the wet battery "cells" you described are not considered individual batteries when the battery "cells" are connected with cable leads and function as a single battery. Determining whether the packaging meets the definition of a bulk or non-bulk packaging will depend on the size and weight of the assembled battery.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division


Regulation Sections

Section Subject
171.8 Definitions and abbreviations