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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 #99-0280 ([Challenger Transportation, Inc.] [Mr. Jeff K. Ehrman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Challenger Transportation, Inc.

Individual Name: Mr. Jeff K. Ehrman

Location State: MO Country: US

View the Interpretation Document

Response text:

December 2, 1999


Mr. Jeff K. Ehrman                       Ref. No. 99-0280
Challenger Transportation, Inc.
P.O. Box 247
Clinton, MO 64735

Dear Mr. Ehrman:

This is in response to your letter dated October 6, 1999, regarding the shipment of electric storage batteries under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if electric storage batteries meeting the criteria specified in § 173.159(e) are subject to placarding when shipping papers are provided (e.g., Batteries, wet, filled with acid, 8, UN2794, PG III).

The answer is no.  Under § 173.159(e), electric storage batteries must: (1) be the only hazardous material on the vehicle; and (2) be loaded or braced so as to prevent damage and short circuits.  In addition, any other material loaded in the vehicle must be blocked and braced to prevent contact with or damage to the batteries and the vehicle may not carry material shipped by any person other than the shipper of the batteries.  Electric storage batteries meeting the criteria specified in § 173.159(e) are not subject to the HMR.  The HMR include, but are not limited to, shipping paper, marking, labeling, and placarding requirements. If the shipper chooses to provide a hazardous materials shipping paper, the shipper must do so in accordance with all the requirements in Part 172, Subpart C; however, the vehicle need not be placarded.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.159 Batteries, wet