American Suzuki Motor Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. esearch and Washington, D.C. 20590 aminstration MAR 3 0 2000 Mr. Werner Dittmer American Suzuki Motor Corporation Ref. No. 00-0060 P.O. Box 1100 Brea, CA 92822-1100 Dear Mr. Dittmer: This is in response to your letter dated February 18, 2000 under the Hazardous Materials Regulations (HMR; 49 CFR Parts regarding the marking requirements for non-spillable batteries 171-180). Specifically, you ask if a sticker with the words "NONSPILLABLE" or "NONSPILLABLE BATTERY" would qualify as plainly and durably marked (§ 173.159). Section 173.159 (d) (2) requires each non-spillable battery and "NONSPILLABLE" or "NONSPILLABLE BATTERY" if the battery was its outer packaging to be plainly and durably marked manufactured after September 30, 1995. Any method that manner is acceptable. affixes the required markings to the package in a durable the package during transportation, the use of a sticker is Provided the required marks remain on authorized. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 000060 173.159 -#

Page 2FEB. 18.2000 9:48AM ASMC PARTS & ACCY IU.11M § SUZUKI AMERICAN SUZUMI MOTOR CORPORATION BAH PARTS & ACCESSORIES $173.159 Rebruary 18, 2000 00-0060 Edward Mazzullo Director, Office of Hazardous Materials Standards DHM-10 RSPA 400 ' St. SW Washington, D.C. 20590-0001 Dear Mr. Mazzullo, This is a request for an interpretation regarding DOT regulation 173.159 (d)(2), concerning nonspillable batteries. It reads as follows: "For batteries manufactured after September 30, 1995, the battery and the outer packaging must be plainly and durably marked "NONSPILLABLE" or "NONSPILLABLE BATTERY". Can you please clarify what constitutes "plainly and durably marked"? Does a sticker qualify as a durable marking (for non-spillable), or must the marking be engraved/stamped in the battery in some fashion? dia catiot provided an approved label at tola time, and bas advised that wo ask DOT for I would appreciate a response as soon as possible as we are not able to ship these batteries to our dealers. Thank you, Warm Dillima Werner Dittmer American Suzuki Motor Corporation --___..__#