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The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a June 5th Interpretive Letter clarifying the Hazardous Materials Regulations (“HMR”) applicable to United Nations specification packaging exceptions for lithium cells and batteries.
PHMSA was responding to a request for clarification from Tesla.
Tesla asked whether there is a definition for “strong, impact-resistant outer casing” in the HMR?
PHMSA responds in the negative, stating there is not a specific definition for “strong, impact-resistant outer casing” in the HMR.
Section 173.185(b)(5) allows shippers to package lithium cells or batteries, weighing 12 kg or more with strong, impact-resistant outer casing, using alternative packaging that demonstrates equivalency to the performance standards of Packing Group (PG) II.
In addition, PHMSA notes that lithium cells or batteries:
- Must be secured to prevent damage caused by inadvertent shifting.
- Terminals must not support the weight of other superimposed elements.
- Packaging must prevent short circuits.
PHMSA states that it has previously interpreted the meaning of “strong, impact-resistant outer casing” for these batteries. It is the shipper’s responsibility to ensure the packaging, enclosures, or other handling devices meet necessary performance standards (i.e., to withstand normal conditions incident to transportation).
A copy of the Interpretive Letter can be downloaded here.
