{"operation":"document","citation":"09-0135R","title":"Pinella County Utilities — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-11-25","effective_on":null,"summary":"09-0135R response to Pinella County Utilities concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0135r.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0135r.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0135r","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090135R.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department ofTransportation Pipeline and Hazardous Materials\nSafety Administration\nNOV 2 5 2009\n1200 New Jersey Avenue. SE\nWashington. DC 20590\nMr. Josh Lynch\nPinella County Utilities\n2990 1l0th Ave. North\nSt. Petersburg, FL 33716\nRef. No. 09-0135R\nDear Mr. Lynch:\nRecently, our Office issued several letters, including our June 23, 2009 letter (Ref. No. 090135)\nresponding to your request, regarding the applicability of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) to the transport of used or spent dry cell\nbatteries. This letter supersedes the response given in our June 23, 2009 letter.\nAfter further consideration and analysis ofdry battery chemistries and sizes and based on\ninformation available to us, it is the opinion of this Office that used or spent dry, sealed\nbatteries of both non-rechargeable and rechargeable designs, described as \"Batteries, dry,\nsealed, n.o.s.\" in the Hazardous Materials Table in § 172.1 0 I ofthe HMR and not\nspecifically covered by another proper shipping name, with a marked rating up to 9-volt are\nnot likely to generate a dangerous quantity of heat, short circuit, or create sparks in\ntransportation. Therefore, used or spent batteries ofthe type \"Batteries, dry, sealed, n.o.s.\"\nwith a marked rating of9-volt or less that are combined in the same package and transported\nby highway or rail for recycling, reconditioning, or disposal are not subject to the HMR.\nNote that batteries utilizing different chemistries (i.e., those battery chemistries specifically\ncovered by another proper shipping name) as well as dry, sealed batteries with a marked\nrating greater than 9-volt may not be combined with used or spent batteries ofthe type\n\"Batteries, dry, sealed, n.o.s.\" in the same package. Note also, that the clarification provided\nin this letter does not apply to batteries that have been reconditioned for reuse.\nI hope this information is helpful. If you have further questions, please contact this office.\nSincerely,\n·Iltf.~b~£\nCharles E. Betts,\nhief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\n':';(}htf)(Mh\nBOARD OF COUNTY\nCOMMISSIONERS\n~ 1'13, /59\nNancy Bostock\nNeil Brickfield\n~ It:l r /Ot\nCalvin Harris\nSusan Latvala\n13ct +Ierie.s\nJohn Morroni\nKaren Williams See! CJ9-DI30\nKenneth T. Welch\n05/21109\nRe: Battery Recycling Advisory Letter\nAttn: PHH-IO\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nEast Building\n1200 New Jersey A venue, SE.\nWashington, DC 20590-0001\nTo whom it may concern at the U.S. DOT,\nMy name is Josh Lynch and I'm writing in regards to the DOT PHMSA battery recycling advisory letter that was sent\nout on April3rd ofthis year. I work for a household hazardous waste (HHW) facility in Pinellas County that currently collects\nbatteries from the public. I am currently their Utilities Chemist.\nI have been in contact with Daniel Derwey, your senior hazardous materials investigator, and he has instructed me to\nsend a formal letter and pictures of how we intend to transport our alkaline batteries. I have already received positive vocal\naffirmation for this but need something in writing stating approval. Our contractor also has shown their consent.\nFor our non-rechargeable batteries (AA, AAA, C, D. and 9-volt) we will be placing them compactly, positive face up in\na box to ensure that no movement occurs during shipment which could lead to a short circuit or possible chemical Jeakage (see\npicture). From there we will be closing and sealing said boxes. From there we will proceed one of two ways:\n1) Once they are properly sealed we will then proceed to stack them in a lined (plastic lining) 55 gallon sealable metal\ndrum. The boxes are uniform and large enough that each corner of the box will touch the side of the plastic lined drum - each\ndiagonal ofthe box will equal the diameter ofthe drums width to ensure a compact fit (see picture). or\n2) After they ate boxed and sealed we will palletize and shrink wrap these 12\" x 12\" x 2\" boxes about 3 to 4 stacks high.\nThis lower height stack will ensure that the batteries weight wont become too much ofa factor.\nAs stated I just need written confirmation that this packing process complies with DOT standards for shipping alkaline\nbatteries and was given this address. Ifyou could respond in a timely manner it would be greatly appreciated. You can e-mail\nme at ilynch@pinelJascountv.org or mail me back at:\nJosh Lynch\n2990 11Oth Ave. North\nSt; Petersburg, FL 33716\n1\nPhone: (727) 464-7735 \"\n,\nilynch@pinellascounty.org\n,r' \"\n\", . '\" . I '. . ,. ~I\nJ' ,; 1'_ \"'''' ':'('.. \"\n,\" \" ,\n\n<<<PAGE 3>>>\n\nn :P\n0\n0 \"'0\n~ :0 \"'0\nU'J m m\n-l (,{~ ::n\n<fl\n!\"\n~\n~\n\n<<<PAGE 4>>>\n\n16110\n\n<<<PAGE 5>>>\n\nNE","truncated":false,"body_characters":4698}