Interpretation Response #98-0602 ([G.H. Johnson & Associates, Inc.] [Mr. James A. Noone])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: G.H. Johnson & Associates, Inc.
Individual Name: Mr. James A. Noone
Location State: DC Country: US
View the Interpretation Document
Response text:
APR 17, 1998
Mr. James A. Noone
G.H. Johnson & Associates, Inc.
1211 Connecticut Avenue, N.W., Suite 302
Washington, D.C. 20036-2603
Dear Mr. Noone:
This is in response to your letter of March 25, 1997, requesting clarification on the shipping requirements for batteries manufactured by your company under the provisions of the Hazardous Materials Regulations (.IDvfR; 49 CFRParts 171-180). Specifically, you ask if your batteries are subject to the HMR.
The information you provided demonstrates that your batteries are constructed in such amannerthat the sulfuric acid electrolyte is completely sealed and cannot leak even if the battery is cracked open or punctured. In addition, the sulfuric acid electrolyte is absorbed in a fibrous glass separator. Thus, your batteries appear to meet the criteria for non-spillable batteries in § 173 .159( d). When securely packaged and protected against short circuits, non-spillable batteries are not subject to the provisions of the Hazardous Materials Regulations.
In addition, under the International Civil Aviation Organization's (ICAO) Technical Instructionsfor the Safe Transport of Dangerous Goods by Air, special provision A67, a non-spillable battery is considered to be non-regulated if, at a temperature of 55°C, the electrolyte will not flow from a cracked or ruptured case.
I hope that this information is helpful. If you need further assistance, please contact us.
Sincerely,
Delmer F. Billings
Chief Regulations Development
Office of Hazardous Materials Standards
173.159
Regulation Sections
| Section | Subject |
|---|---|
| 173.159 | Batteries, wet |