{"operation":"document","citation":"03-0219","title":"Department of the Navy — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-09-25","effective_on":null,"summary":"03-0219 response to Department of the Navy concerning 173.159.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0219.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0219.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0219","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030219.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nSEP 25 2003\nMr. Daniel J. Burke\nRef No.: 03-0219\nActing Head, Environmental, Safety\nand Security Department\nDepart of the Navy\nNaval Undersea Warfare Center Division\n1176 Howell Street\nNewport RI 02841-1708\nDear Mr. Burke:\nThis is in responds to your letter and subsequent telephone conversation with Gigi Corbin of my staff,\nrequesting clarification of § 173.159(c)(1) of the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). Specifically you asked whether you may ship Batteries, wet, filled with alkali, 8, UN\n2795, PG III under the provisions of § 173.159(c)(1) via rail, highway or vessel.\nAccording to your letter, you are shipping 200 batteries in the original manufacturer's crate or in similar\nnewly constructed crates. The batteries will be packed and secured in a manner to prevent any of the\nbattery terminals from supporting the superimposed weight. In addition, the crates will be secured to\npallets or skids with banding. The estimated weight of the batteries, pallet or skid, and crate is 1100\nIbs. Section 173.159(c)(1) allows electric storage batteries protected against short circuits and firmly\nsecured to skids or pallets capable of withstanding the shocks normally incident to transportation to be\ntransported by rail, highway, or water. The height of the completed unit must not exceed 1 ½ times the\nwidth of the skid or pallet. The unit must be capable of withstanding, without damage, a superimposed\nweight equal to two times the weight of the unit or, if the weight of the unit exceeds 907 kg (2000\npounds), a superimposed weight of 1814 kg (4000 pounds). Battery terminals must not be relied upon\nto support any part of the superimposed weight. Provided all provisions in § 173.159(c)(1) are met,\nyour understanding is correct.\nI hope this information is helpful. Plcase contact us if you require additional assistance\nSincerely,\nWhoa Dol\nSusan Gorsky\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n173.159\n030219\n\n<<<PAGE 2>>>\n\nRelerford\nDEPARTMENT OF THE NAVY\nNAVAL UNDERSEA WARFARE CENTER DIVISION\n$173. 159(0)\nNEWPORT RI 02841-170B\n1176 HOWELL STREET\nBatteries\nIN REPLY REFER TO:\n5090\n03-0219\nSer 3551/75\nMr. Edward Mazzullo\nUSDOT/RSPA/DHM10\nDirector, Office of Hazardous Material Standards\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nDear Mr. Mazzullo:\nof preparing a procedure for shipping silver-zinc batteries\nThe Naval Undersea Warfare Center (NUWC) is in the process\nJuly 29, 2003, phone call with Ms. Gigi Corbin in your Office of\ncontaining Potassium Hydroxide (KOH) .\nDuring a\nHazardous Materials Safety, NUWC received verbal approval for\nshipping silver-zind batteries containing KOH under the\nconversation, Ms. Corbin consulted with another member of her\nregulatory requirements of 49 CFR $ 173.159 (c) (1). During that\noffice, Mr. John Gale, who agreed with that approval.\nensure our\ncompliance with the intent of the Hazardous Materials\nwritten verification\nfrom your office in order to\nRegulations (HMR) .\nNUWC facilities use rechargeable silver-zino batteries for\nundersea warfare research, development, test, and evaluation\nbatteries, measuring 1.5 x 6 x 6.5 inches, are manufactured and\nrate of approximately 5000-6000 cells annually.\ntested to\nmanufacturer to the operational sites,\nstrict military specifications.\nthe batteries are dry.\nwhen shipped from the\nTwo hundred batteries are packaged and shipped in a single non-\nNUW facilities before initial use. Each wet battery has a\nspecification crate. The batteries are filled with KOH at the\nmaximum weight of 4.55 pounds.\nAfter approximately two years of use, the batteries are no\ndischarged with the polive and hegae a term none comicted\nsalvageable.\ncharge and possibly causing a short circuit during packing,\nwith a jumper wire to prevent\nthe batteries from developing a\nshipping, and unpacking.\nHawthorne, Nevada for reclamation.\n\n<<<PAGE 3>>>\n\nSer 3551/75\n5090\nfollows:\nour proposed procedure for shipping these batteries is as\noriginal manufacturer's crate or in a\na.\nNo more than 200 batteries will be re-packaged in the\ncrate.\nThe crates will meet the superimposed weight\nsimilar newly constructed\nand\nrequirements of the regulation.\nsecured in a manner to prevent any of the battery terminals\nThe batteries will be packed\nsecured to the pallet or skid with banding. The estimated\nfrom supporting the superimposed weight\nThe crate will then be\npounds.\nweight of the batteries, pallet or skid, and crate is 1100\nrequirements of the regulation.\nThe completed unit will comply with the dimension\nproper shipping name stipulated in the 49 CFR § 172.101\nThe skid or pallet of batteries will be marked with the\nlazardous Materials Table; specifically,\nwith alkali, 8, UN2795\".\nThey will be labeled as\n\"Batteries, wet, filled\nwith arrow up indicators.\n\"Corrosive\"\nusing the proper shipping name and all other applicable HMR\nA shipping document will be prepared\nrequirements.\nrequest, or any recommended modifications, you may direct them\nIf you have any questions regarding our proposal or this\nat (401) 832-5858.\nto Mr. Noel (Mac) Field in our Hazardous and Solid Waste Program\nto your reply.\nThank you for your assistance on this issue. I look forward\nSincerely,\nDaniel 2. Burke\nD. J. BURKE\nSafety and Security Department\nActing Head, Environmental,\nBy direction of the Commander\nCopy to:\nNUWCDIVKPT Code L\nPMS401 (E. Sutton)\nNUWCDIVKPT Code 30 (G. Cooper)\n(R. Jusko)\nNUWCDIVKPT Code 80 (D. Kohn)\nNUWDIVKPT Code 325 D. Herzog:\nJ. Kucera)","truncated":false,"body_characters":5633}