PHMSA Acknowledges It Did Not Intend to Restrict Use of The MOTS Provisions In §173.6 For Lithium Batteries and Other Affected Articles.

摘要

In April of this year, the Dangerous Goods Advisory Council (DGAC) requested guidance from PHMSA concerning the applicability of § 173.6 Materials of Trade (MOTs) exceptions to articles such as lithium batteries. Since lithium batteries and other articles are not assigned a packing group in the § 172.101 Hazardous Materials Table, they are not covered under the gross mass or capacity limits specified in § 173.6(a)(1). DGAC requests guidance on what packaging gross mass limits exist for these materials. DGAC recommends such limits should be consistent with those for materials addressed under § 173.6(a)(1)(H), and suggests the regulatory limits in§ 173.6(a)(l)((ii) could be revised to read: 30 kg (66pounds) or 30 L (8 gallons) for a Packing Group Ⅱ, Pacing Group Ⅲ, or ORM-D material, or a Class 9 material for which a Packing Group is not indicated.