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Interpretation Response #98-0228 ([American Power Conversion] [Mr. Neil Rasmussen])

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

Interpretation Response Details

Response Publish Date:

Company Name: American Power Conversion

Individual Name: Mr. Neil Rasmussen

Location State: MA Country: US

View the Interpretation Document

Response text:

JUN 28, 1999


Mr. Neil Rasmussen                                Ref. No. 98-0228
Vice President, Chief Technical Officer
American Power Conversion
755 Middlesex Turnpike
Billerica, MA 01821-3945

Dear Mr. Rasmussen:

This is in response to your letter dated July 31, 1998, requesting clarification on shipping batteries manufactured by your company under the provisions in §173.159(d) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you are requesting clarification on whether your shipping scenario meets the requirements of § 173.159(d),which require batteries to be protected against short circuits and securely packaged.

According to your letter, your shipping scenario is as follows:

A product with a sealed lead-acid battery is shipped with the battery installed in the product and connected by wires to a printed wiring board, assembly where the high power battery connections of both polarities of the battery are directly connected to multiple adjacent exposed copper pads and traces and to various electronic components.  The exposed connections may be bridged by foreign matter in such a way that the foreign matter or the electrical components could become energized and dissipate sufficient power to generate combustion. Combustion is demonstrated to trigger a sustained electrical fire not limited by a protective device.

Section 173.159(d) does not address the situation where a battery is connected to a device (product).  The scenario described above indicates that the batteries as packaged may allow combustion and short circuits to take place.  It is the opinion of this Office that the configuration of a battery connected to a device (product) as described in your letter, does not provide protection to prevent a short circuit.

I hope this answers your inquiry.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.159 Batteries, wet