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Interpretation Response #08-0086

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 05-13-2008
Company Name: EnerSys    Individual Name: Mr. Tom Biello
Location state: PA    Country: US

View the Interpretation Document

Response text:

May 13, 2008





Mr. Tom Biello

Director, Supply Chain


2366 Bernville Road

Reading, PA 19605


Ref. No. 08-0086


Dear Mr. Biello:


This responds to your letter requesting clarification of the packaging requirements for batteries under the International Maritime Dangerous Goods Code (IMDG Code) as authorized for use under § 171.22 of the Hazardous Materials Regulations (49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:


Q1.      Occasionally our company offers for international transportation, by vessel, forklift batteries that weigh approximately 2,000 lbs each.  The batteries are packaged under Packing Instruction P801 of the IMDG Code.  Packing Instruction P801 requires the batteries to be packaged in one of the following types of packaging: (1) rigid outer packagings; (2) wooden slated crates; or (3) pallets.  Our company secures the batteries to wooden pallets with steel banding material.  Does this method comply with Packing Instruction P801 of the IMDG Code?

A1.      Yes.  Your packaging method conforms to the third option in your question.

Q2.      If we choose the second option (wooden slated crate) in Q1 to package our batteries, is absorbent material required?

A2.      No, Packing Instruction P801 of the IMDG Code does not require absorbent material for any of the authorized types of packagings.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.



Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

171.22 173.159

Regulation Sections

Section Subject
§ 171.22 Authorization and conditions for the use of international standards and regulations