# Pinella County Utilities — Hazardous Materials Safety Interpretation **Citation:** 09-0135R **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2009-11-25 09-0135R response to Pinella County Utilities concerning 172.101. ## Document text <<>> U.S. Department ofTransportation Pipeline and Hazardous Materials Safety Administration NOV 2 5 2009 1200 New Jersey Avenue. SE Washington. DC 20590 Mr. Josh Lynch Pinella County Utilities 2990 1l0th Ave. North St. Petersburg, FL 33716 Ref. No. 09-0135R Dear Mr. Lynch: Recently, our Office issued several letters, including our June 23, 2009 letter (Ref. No. 090135) responding to your request, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transport of used or spent dry cell batteries. This letter supersedes the response given in our June 23, 2009 letter. After further consideration and analysis ofdry battery chemistries and sizes and based on information available to us, it is the opinion of this Office that used or spent dry, sealed batteries of both non-rechargeable and rechargeable designs, described as "Batteries, dry, sealed, n.o.s." in the Hazardous Materials Table in § 172.1 0 I ofthe HMR and not specifically covered by another proper shipping name, with a marked rating up to 9-volt are not likely to generate a dangerous quantity of heat, short circuit, or create sparks in transportation. Therefore, used or spent batteries ofthe type "Batteries, dry, sealed, n.o.s." with a marked rating of9-volt or less that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal are not subject to the HMR. Note that batteries utilizing different chemistries (i.e., those battery chemistries specifically covered by another proper shipping name) as well as dry, sealed batteries with a marked rating greater than 9-volt may not be combined with used or spent batteries ofthe type "Batteries, dry, sealed, n.o.s." in the same package. Note also, that the clarification provided in this letter does not apply to batteries that have been reconditioned for reuse. I hope this information is helpful. If you have further questions, please contact this office. Sincerely, ·Iltf.~b~£ Charles E. Betts, hief, Standards Development Office of Hazardous Materials Standards <<>> ':';(}htf)(Mh BOARD OF COUNTY COMMISSIONERS ~ 1'13, /59 Nancy Bostock Neil Brickfield ~ It:l r /Ot Calvin Harris Susan Latvala 13ct +Ierie.s John Morroni Karen Williams See! CJ9-DI30 Kenneth T. Welch 05/21109 Re: Battery Recycling Advisory Letter Attn: PHH-IO U.S. DOT PHMSA Office of Hazardous Materials Standards East Building 1200 New Jersey A venue, SE. Washington, DC 20590-0001 To whom it may concern at the U.S. DOT, My name is Josh Lynch and I'm writing in regards to the DOT PHMSA battery recycling advisory letter that was sent out on April3rd ofthis year. I work for a household hazardous waste (HHW) facility in Pinellas County that currently collects batteries from the public. I am currently their Utilities Chemist. I have been in contact with Daniel Derwey, your senior hazardous materials investigator, and he has instructed me to send a formal letter and pictures of how we intend to transport our alkaline batteries. I have already received positive vocal affirmation for this but need something in writing stating approval. Our contractor also has shown their consent. For our non-rechargeable batteries (AA, AAA, C, D. and 9-volt) we will be placing them compactly, positive face up in a box to ensure that no movement occurs during shipment which could lead to a short circuit or possible chemical Jeakage (see picture). From there we will be closing and sealing said boxes. From there we will proceed one of two ways: 1) Once they are properly sealed we will then proceed to stack them in a lined (plastic lining) 55 gallon sealable metal drum. The boxes are uniform and large enough that each corner of the box will touch the side of the plastic lined drum - each diagonal ofthe box will equal the diameter ofthe drums width to ensure a compact fit (see picture). or 2) After they ate boxed and sealed we will palletize and shrink wrap these 12" x 12" x 2" boxes about 3 to 4 stacks high. This lower height stack will ensure that the batteries weight wont become too much ofa factor. As stated I just need written confirmation that this packing process complies with DOT standards for shipping alkaline batteries and was given this address. Ifyou could respond in a timely manner it would be greatly appreciated. You can e-mail me at ilynch@pinelJascountv.org or mail me back at: Josh Lynch 2990 11Oth Ave. North St; Petersburg, FL 33716 1 Phone: (727) 464-7735 " , ilynch@pinellascounty.org ,r' " ", . '" . I '. . ,. ~I J' ,; 1'_ "'''' ':'('.. " ," " , <<>> n :P 0 0 "'0 ~ :0 "'0 U'J m m -l (,{~ ::n >> 16110 <<>> NE ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `e5aea4048bd141ce7dacc59414df574cd64ee03afd69ee236079ab1b53eb7b0f` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-22T08:01:37.214Z - Document slug: `phmsa-interpretation-09-0135r` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "Pinella County Utilities" ], "individuals": [ "Mr. Josh Lynch" ], "refIds": [ "09-0135R" ], "catalogDates": [ "2009-11-25" ], "catalogParts": [ 172 ], "catalogRowCount": 1, "sourceRecordUrls": [ "https://www.phmsa.dot.gov/node/52141" ], "linkedAttachmentUrls": [], "unavailableResponseUrls": [], "duplicateRepresentationUrls": [], "citedSections": [ "172.101", "172.1" ], "catalogPageUrls": [ "https://www.phmsa.dot.gov/regulations/title49/section/172101" ], "pdfUrls": [ "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090135R.pdf" ], "representations": [ { "viewUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090135R.pdf", "detailUrl": null, "detailHtmlPath": null, "pdfUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090135R.pdf", "pdfArtifactPath": "data/sources/phmsa-interpretations/09-0135r-a89e8d9c42.pdf", "pdfArtifactSha256": "392b21460bc85d28ff0e54a07faf107f7d16bcd3b572127a9c9d633390cedf17", "extractedTextPath": "data/sources/phmsa-interpretations/09-0135r-a89e8d9c42.v2.txt", "extractedTextSha256": "69c35c658f69f9477fab0e920b5e3bf42ee32a828eb217103d7771b4078b6fef", "pageCount": 5, "extractionVersion": 2 } ], "caveat": "Interpretations apply regulations to the facts presented and do not create independently enforceable requirements.", "jurisdiction": "US" } ```