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Interpretation Response #21-0048

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

Interpretation Response Details

Response Publish Date:

Company Name: EnerSys

Individual Name: Steven Spease

Location State: PA Country: US

View the Interpretation Document

Response text:

July 6, 2021

Mr. Steven Spease
Packaging Compliance Engineer
EnerSys
2366 Bernville Rd
Reading, PA  19605

Reference No. 21-0048

Dear Mr. Spease:

This letter is in response to your May 5, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging requirements for lithium ion batteries shipped for disposal or recycling in accordance with § 173.185(d). Specifically, you describe a large lithium ion battery weighing 12 kg or more with a strong impact resistant outer casing typically transported on a pallet or handling device in accordance with § 173.185(b)(5). You ask whether this battery may be transported on a pallet or handling device without being placed into a strong outer packaging when it is moved for recycling or disposal in accordance with § 173.185(d).

The answer is yes. Large lithium batteries weighing 12 kg or more—with a strong impact resistant outer casing—may be packaged in accordance with the instructions in § 173.185(b)(5) when transported for recycling or disposal in accordance with § 173.185(d). The provisions in in paragraph (d) provide an exception for lithium batteries shipped for disposal or recycling from testing and record keeping requirements of paragraph § 173.185(a) and the UN performance packaging requirements. This provision would not preclude the use of alternative packagings under the conditions described in § 173.185(b)(5).

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

Sincerely,

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

173.185(a), 173.185(b)(5), 173.185(d)

Regulation Sections

Section Subject
173.185 Lithium cells and batteries