{"operation":"document","citation":"08-0161","title":"Portable Rechargeable Battery Association — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-07-29","effective_on":null,"summary":"08-0161 response to Portable Rechargeable Battery Association concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0161.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0161.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0161","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080161.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave , S E\nWashington, DC 20590\nJllL 29 2008\nMr. George Kerchner\nExecutive Director\nPortable Rechargeable Battery Association\n1776 K Street, NW\nWashington, DC 20006\nRef. No.: 08-0161\nDear Mr. Kerchner:\nThis is in response to your June 3,2008 electronic mail requesting clarification of the\npackaging requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 -\n180) and the various international dangerous goods regulations pertaining to lithium batteries.\nSpecifically, you ask if a shipper may use strong outer packagings, protective enclosures or\npallets instead of UN combination packages provided certain requirements are met.\nAs provided by 5 173.185(g) and Packing Instruction 903 of the International Civil Aviation\nOrganization Technical Instructions and the International Maritime Dangerous Goods Code,\nbatteries employing a strong, impact-resistant outer casing and exceeding a gross weight of 12\nkg (26.5 lbs.), and assemblies of such batteries, may be packed in strong outer packagings, in\nprotective enclosures (for example, in fully enclosed wooden slatted crates) or on pallets.\nBatteries must be secured to prevent inadvertent movement, and the terminals may not\nsupport the weight of other superimposed elements. Batteries packaged in this manner are\nnot subject to specification packaging requirements but are subject to the other requirements\nof 173.185(a) or Packing Instruction 903 including shoi-t circuit protection and design type\ntesting.\nBatteries packaged in the manner described above may be transported by highway, rail, and\nvessel. Such batteries are not permitted for transportation by passenger aircraft, and may be\ntransported by cargo aircraft only if approved by the Associate Administrator prior to\ntransportation.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nSusan Gorsky\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nPORTABLE\nRECHARGEABLE\nBATTERY\nASSOCIATION\nJune 6,2008\nMs. Carolyn Drakeford\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Avenue, SE\nWashington, DC\nRe: Request for Interpretation on ICAO TI PI 903 and 49 CFR 173.18Xa)\nDear Ms. Drakeford:\nAs a follow-up to my June 3 email to your office, I am writing for a clarification on the provision found\nin the lithium battery regulations at 49 CFR 173.1 85(g). A similar provision is in Packing Instruction 903 of the\nIMDG Code and Packing Instruction 903 of the ICAO Technical Instructions.\n49 CFR 173.185(g) and Packing Instruction 903 state that \"Batteries employing a strong, impact-\nresistant outer casing and exceeding a gross weight of 12 kg (26.5 lbs.), and assemblies of such batteries, may\nbe packed in strong outer packagings, in protective enclosures Cfor example, in fully enclosed wooden slatted\ncrates) or on pallets. Batteries must be secured to prevent inadvertent movement, and the terminals may not\nsupport the weight of other superimposed elements. Batteries packaged in this manner are not permitted for\ntransportation by passenger aircraft, and may be transported by cargo aircraft only if approved by the\nAssociate Administrator prior to transportation.\" Large lithium batteries normally must be shipped in Packing\nGroup I1 packaging. However, this provision at 49 CFR 173.185(g) and in Packing Instruction 903 appear to\nauthorize shippers to use strong outer packagings, or protective enclosures (for example, in fully enclosed\nwooden slatted crates,) or pallets instead of Packing Group I1 packaging if the battery exceeds 12 kg and has an\nimpact-resistant outer casing. 1 recognize that the battery also is subject to the UN testing requirements.\nTherefore, my question is -\nMay a shipper use strong outer packagings, or protective enclosures (for example, in fully enclosed\nwooden slatted crates,) or pallets instead of Packing Group I1 packaging to ship a lithium battery if it exceeds 12\nkg, has an impact-resistant outer casing, and has passed the required LIN lithium battery tests?\nI can be reached at 202.719.4.109 if you have any questions. Thank you for your assistance.\nSincerely,\nGeorge A. Kerchner\nExecutive Director\n1776 K Street, NW\nWashington, DC 20006\n202.719.4978","truncated":false,"body_characters":4400}