Pride Mobility Products Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Research and OCT 11 2002 400 Seventh St., S.W. Washington, D.C. 20590 Spint train s Mr. Robert Aulisio Pride Corporate Safety Director Reference No. 02-0261 P82 Suguehana Avenu Corporation Exeter, PA 18643-2694 Dear Mr. Aulisio: This is in response to your September 19, 2002 letter requesting clarification of the provisions in § 173.220 of the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically, you ask if a non-spillable battery contained in a wheelchair is subject to the requirements of the HMR. The answer is no, battery powered wheelchairs and mobility aids equipped with a non-spillable wet clectric storage battery and containing no other hazardous materials are not subject to the requirements of the HMR when transported by rail, highway or vessel. The non-spillable battery must meet the criteria in § 173.159(d) and must be marked "NONSPILLABLE" or "NONSPILLABLE BATTERY." In addition, the battery must be securely installed and fastened in an upright position, and properly protected from short circuits when contained in the equipment. I hope this satisfies your request. Sincerely, Hothe I Mithe l Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 020261#

Page 2182 Susquehanna Avenue /Pride Exeter, PA 18643-2694 570-655-5574 FAX 570-655-4305 Mobility Products Corp. www.pridemobility.com Betts §П3.154 September 19,2002 $ 173.220 Batteries Mr. Edward Mazzullo 02-0261 Director, Office of Hazardous Material Standards 400 7' Street S.W. U.S. DOT/RSPA (DHM-10) Washington, D.C. 20590-0001 Dear Mr.Mazzullo, The company I work for produces powered mobility equipment such as powered wheelchairs regulations concerning this equipment (49 CFR 173.220 & 173.159) and understand that we are and scooters. A 12-volt non-spillable battery powers our equipment. I have reviewed the excepted from the regulations as long as the batteries are secured and protected against arcs, sparks and short circuits. We are looking into connecting the batteries on the units when shipping them out. Is this acceptable as long as we follow the exceptions in the above referenced regulations? My manager would like to have a letter from your office stating if this is acceptable or not. Please send your correspondence to the address listed above and to my attention. incere Polet Aulise Pride Corporate Safety Director Robert Aulisio#