{"operation":"document","citation":"08-0202","title":"Mr. Carl Severn — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-10-14","effective_on":null,"summary":"08-0202 concerning 172.101, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0202.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0202.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0202","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080202.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave.. SE\nWashington, DC 20590\nMr. Carl Severn\n12596 W Bayaud Avenue, Suite 2 10\nLakewood, Colorado 80228\nRef. No. 08-0202\nDear Mr. Severn:\nThis is in response to August 5,2008 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171 - 180). You provide six common battery\ntypes and the proper shipping description that you believe is appropriate for each. You ask\nthat we confirm the proper shipping descriptions for each of the six battery types. The battery\ntype and your description for each are summarized as follows:\n1. Nickel-Cadmium batteries (dry, typically for appliances, toys, and cordless phones).\nProper shipping description: Battery, dry, not subject to the requirements of this subchapter.\n2. Nickel-Cadmium batteries (wet)\nProper shipping description: Batteries, wet, filled with alkali, 8, UN3028,III\n3. Alkaline Batteries (common AA, D, and C cell batteries)\nProper shipping description: Battery, dry, not subject to the requirements of this subchapter\n4. Lithium-manganese dioxide batteries (found in phones and digital cameras)\nProper shipping description: Lithium battery, 9, UN3090, I1\n5. Lithium ion button batteries (typically for watches and calculators)\nProper shipping description: Lithium battery, 9, UN3090, I1\n6. Silver oxide batteries (common in watches)\nProper shipping description: Battery, dry, not subject to the requirements of the subchapter\nIt is the shipper's responsibility to properly class and describe a hazardous material in\naccordance with the HMR (see 5 173.22, shipper responsibility). This office does not\nperform that function. However, it is the opinion of this Office that the proper shipping\ndescriptions you have provided for each battery type are appropriate. Please note that\nbatteries described as \"Batteries, dry, not subject to the requirements of this subchapter\"\nmust be securely packaged and offered for transportation in a manner that prevents the\n\n<<<PAGE 2>>>\n\nCarl Severn\n12596 W. Bayaud Avenue, Suite 210 Ft-bioprf 5h;pp;nj dome\nLakewood, Colorado 80228\n0s -0ZoZ\n(303) 526-2674\nAugust 5,2008\nMr. Ed Mazzullo\nU.S. DOT PHMSA\n1200 New Jersey Avenue, SE Building, 2\"* Floor\nWashington, DC 20590\nDear Mr. Mazzullo:\nI am seeking written guidance in regards to 49 CFR 172.101. In particular, I am looking\nfor clarification as to what are the most accurate shipping descriptions for common\nbatteries.\nBelow are listed six common battery types (1-6). Under each type I placed shipping\ndescriptions I feel best describe the battery, the first (A) being my first shipping description\nchoice, the second (B) being my second choice for a shipping description. Please provide\nassistance by identifying the most accurate shipping description for the following battery\ntypes.\nNote: The batteries below are not in their original inner packagings, intended for retail sale.\nRather, they are used and are being collected for disposal or recycling. As well, transport is\nby highway only.\n1) Nickel-cadmium batteries (dry, typically for appliances, toys and cordless phones)\nA) Battery, dry, not subject to the requirements of this subchapter\nB) Batteries, dry, containing potassium hydroxide solid, 8, UN3028, I11\n2) Nickel-cadmium batteries (wet)\nA) Batteries, wet, filled with alkali, 8, UN2795, I11\n3) Alkaline batteries (these are the common AA, C and D cell batteries)\nA) Battery, dry, not subject to the requirements of this subchapter\nB) Batteries, dry, containing potassium hydroxide solid, 8, UN3028,III\n4) Lithium-manganese dioxide batteries (found in phones and digital cameras)\nA) Lithium battery, 9, UN3090, I1\n5) Lithium ion button batteries (typically for watches and calculators)\nA) Lithium battery, 9, UN3090, I1\n\n<<<PAGE 3>>>\n\n6) Silver oxide button batteries (common in watches)\nA) Battery, dry, not subject to the requirements of this subchapter\nB ) Batteries, dry, containing potassium hydroxide solid, 8, UN3028, I11\nAny help would be greatly appreciated.\nSincerely,\nCarl Severn","truncated":false,"body_characters":4102}