Iowa State Patrol Iowa Department of Public Safety — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration July 29, 2026 Sergeant Glenn Goode Iowa State Patrol Iowa Department of Public Safety 215 East 7th Street Des Moines, IA 50319 Reference No. 25-0051 Dear Sgt. Goode: This letter is in response to your April 7, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazmat registration for lithium batteries that comprise a battery energy storage system (BESS). You describe a scenario involving lithium batteries, installed in a Cargo Transport Unit (CTU). The bill of lading enclosed with your letter indicates the dimensions of the cargo transport unit of 19.11 feet long, 8.08 feet wide, and 9.07 feet tall (approximately 1,400 cubic feet), weighing approximately 77,000 pounds. You ask if this cargo transport unit would be considered a bulk packaging under the definition in § 171.8. Yes. As defined in § 171.8, bulk packaging is defined as a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. Because the batteries described in your letter are housed within a single container, and wired together as a single unit, rather than being separated into individual inner packages, the container is considered a bulk packaging. In addition, registration is required under § 107.601(a)(4) for any shipment of hazardous materials in a bulk packaging (see § 171.8 of this chapter) that has a capacity of at least 13.24 cubic meters (468 cubic feet) for solids. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, 1200 New Jersey Avenue, SE Washington, DC 20590 Alexander Wolcott Acting Chief, Regulatory Review & Reinvention Standards and Rulemaking Division#

Page 2Cajar, J. 25-0051 From: Casey, Candace (PHMSA) To: Hazmat Interps Cc: Baker, Yul (PHMSA) Subject: Overweight Cargo Transport Units Date: Thursday, April 24, 2025 15:57:43 Attachments: image002.png image003.png image004.png Hi Yul, can you process this as an incoming interp letter? Thanks! C From: Flattery, James (FMCSA) <James.Flattery@dot.gov> Sent: Monday, April 7, 2025 8:34 AM To: Stiles, Jessica (FMCSA) <jessica.stiles@dot.gov> Subject: FW: Overweight Cargo Transport Units Jess, I took this call from the state last week. We were discussing the different requirements when Sgt. Goode asked about Hazmat Registration in relation to the below trailer. He brought up an interesting point from 107.601(a)(4). Even though a placard would not be needed, it could be argued that this trailer is a type of bulk packaging. The trailer is a portable power station were the lithium cells are wired together during transport. I think a counter point could be made that the individual cells that could fit in your hand negate the bulk packaging definition in 171. But, it they are wired together during transport, would it not be all one unit now? Just curious on what your thoughts were? From: Goode Glenn <goode@dps.state.ia.us> Sent: Friday, April 4, 2025 12:44 PM To: Flattery, James (FMCSA) <James.Flattery@dot.gov> Subject: FW: Overweight Cargo Transport Units CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Sergeant Glenn Goode ★523★ Iowa State Patrol | CMVU HQ Iowa Department of Public Safety 215 East 7th Street | Des Moines, Iowa 50319 Radio: 515-323-4360 Cell: 515-460-2152 Fax: 515-725-6118 goode@dps.state.ia.us https://dps.iowa.gov/ https://dpscareers.com/#

Page 3*NOTICE* This email message (including any file attachments transmitted with it) is for the sole use of the intended recipient(s) and may contain confidential and legally privileged information. Any unauthorized use or disclosure of this email by an unintended recipient is prohibited. If you have received this e-mail in error please notify the sender by return e-mail and destroy all copies of the original message. No representation is made that this email or any attachments are free of viruses. Virus scanning is recommended and is the responsibility of the recipient. From: Goode Glenn Sent: Friday, April 4, 2025 12:07 PM To: Krolak, Tomasz (DPS) <tomasz.krolak@state.mn.us>; Letourneau, Jacob (DPS) <jacob.letourneau@state.mn.us> Subject: FW: Overweight Cargo Transport Units These are what we have stopped…Trucks/trailers weigh between 110,000 pounds and 133,000 pounds.#

Page 4CARRIER: BENNETT MOTOR EXPRESS, LLC STRAIGHT BILL OF LADING- DOT# 92693 ORIGINAL - NOT NEGOTIABLE SHORT FORM 1001 Industrial Parkway McDonough GA 30253 DATE which the above indicated Carrier agrees to carry. It shall be the responsibility of Shipper to load, weigh and count all articles tendered for shipment and to prepare and escribed below, in apparent good order except as otherwise noted (condition of contents of packages unknown), marked, consigned and destined as indicated below Received, subject to the tariff (which are incorporated herein as if fully set forth) in effect on the date of issue of the Bill Of Lading, the property Carrier's Freight Load Number for vibration, water, moisture, dirt, dust, smoke, fumes, or similar cause of damage, caused in whole or in part, by failure of the shipper to property prepare, package moving on open-bed trailer equipment. In no event shall Carrier have any liabilty for damage related to improper and revisions thereof as are other important rules and procedures that may apply to this O THE TERMS AND CONDITIONS OF THIS LO LADING ARE PUBLISHED IN THE ICC DOME 101 RULES TAN PS. Camera ay plan te Shipper's Number authorized or empowered to vary upon request and are or modify any of the terms and conditions contained in this pre-printed Straight Bill of Lading and any attempt to modify, vary of published on www.bennettg.com. No party, including driver. employee. maintained at Carrier's and the same are agreed to by the parties for themselves and their assigns add to the terms and conditions set forth herein by any party shall be null and void Manifest Number FROM (Shipper's Name) All parties hereto (shipper/consignor/consignee) hereby certity that they are familiar with said terms and conditions of the BILL OF LADING and Carrier's rules tarift is to be delivered to the consignee with applicable bill of lading, if this shipment Sublect to Section 7 of conditions of Street Address LOADING SITE 631 WEST 4TH STREET PERRIS City CA State 92570 Zip Code signor shall sign the following statement out recourse on the consonot, the cor freight and all other lawful charges The carrier shall not make delivery of CASEY'S TRUCK SHOP TO (Consignee's Name) payment o Street Address X 9001 6TH STREET SW CEDAR RAPIDS City IA State 52404 Zip Code (Signature of Consignon) Third Party Billing (only if approved by Credit Dept.) either shipper or consone be entitled to collect freight charges from Unless signed above. Carrier shall Street Address City State Zip Code or stamp here. "To Be Prepaid" If Charges are to be prepaid, write Number Kind of Package, Description of Articles, Special Marks, and Exceptions Weight (Subject lo Correction or Ratio Class INSTALLED IN CARGO TRANSPORT UNIT, CLASS 9 1x20HC - STC UN3536 LITHIUM BATERIES, 35000KG 9 unless amount is here specified and rier accepts no such responsibility if Charges are to be C.O.D., the car- this section signed by consignor. C.O.D. Amount UN3536,lithium ion batteries, 9 X (Signature of Consignor) 24 HR Emergency Contact: 86-593-2583668 declared value is specifically stated If shipper declares a value, the $1.00 FOR USED GOODS) PER POUND FOR EACH ARTICLE, NOT TO EXCEED S100,000 PER TRUCKLOAD UNLESS A GREATER VALUE IS DECLARED, SHIPPER HEREBY RELEASES THE VALUE TO $2.50 by shipper not to exceed: mer shall have limited liability for delays for pickup or delivery in accordance with Carrier's Rules Tariff. Carrier shall not be liable for any damage resulting from loss $ use, profit, or business, non-operation or increased expense of operation, service interruption, or for any special, indirect, incidental or consequential damages (subject to excess valuation charge c arges on the shipment which is the basis of such claim. On shipments moving within Mexico. Carrier shall have no liability during any portion of the movement within tier's maximum liability for delay for any cause, whatsoever, and regardless of the form of action (in contract or tort), shall be limited solely to the amount of freight S1 for each $100.00 or portion thereof nths of the delivery date. Nico in relation to the cargo or any components thereof, or to the selection of another carrier Any loss, damage or delay claim must be filed with the Carrier within 9 If credit is extended by Carrier, freight charges are due within 15 days of invoice. Freight charges not paid within 30 days of presentation of freight bill shall be (Signature of Consignor) the unpaid charges or $200.00, whichever is greater. Any suit for the collection of freight charges shall be instituted in Henry County Georgia and the parties hereto subject to a service charge of 1.5% per month on the unpaid balance, and if collected through an attorney-at-law Carrier shall be entitled to attorney's fees of 15% of if Driver is to Collect Freight Charges, consent and submit to the exclusive venue and jurisdiction of the Federal & State Courts located in Henry County, Georgia AMOUNT TO BE COLLECTED BY DRIVER $ ctor No. CARGO Length Height iler No. DIMENSIONS 19.11 8.08 9.07#

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Page 6Sergeant Glenn Goode ★523★ Iowa State Patrol | CMVU HQ Iowa Department of Public Safety 215 East 7th Street | Des Moines, Iowa 50319 Radio: 515-323-4360 Cell: 515-460-2152 Fax: 515-725-6118 goode@dps.state.ia.us https://dps.iowa.gov/ https://dpscareers.com/ *NOTICE* This email message (including any file attachments transmitted with it) is for the sole use of the intended recipient(s) and may contain confidential and legally privileged information. Any unauthorized use or disclosure of this email by an unintended recipient is prohibited. If you have received this e-mail in error please notify the sender by return e-mail and destroy all copies of the original message. No representation is made that this email or any attachments are free of viruses. Virus scanning is recommended and is the responsibility of the recipient.#