[NTLK] Need help: Restrictions regarding postal transport of batteries and devices containing batteries in the USA

Tue Apr 25 19:05:08 EDT 2017

Frank,

Here is what I found regarding NiMH batteries in US Postal Service
Publication 52  Publication 52, Hazardous, Restricted, and Perishable Mail
<http://pe.usps.com/text/pub52/welcome.htm> > 3 Hazardous Materials
<http://pe.usps.com/text/pub52/pub52c3_001.htm#ep940089> > 34 Mailability
by Hazard Class <http://pe.usps.com/text/pub52/pub52c3_019.htm#ep898620> > 348
Corrosives (Hazard Class 8)
<http://pe.usps.com/text/pub52/pub52c3_026.htm#ep899998>

Extract with appropriate areas highlighted in red

348.1 Definition

A *corrosive* is any liquid or solid that causes visible destruction or
irreversible alteration in human skin tissue at the site of contact, or a
liquid that has a severe corrosion rate on steel. The term “corrosive”
includes all items commonly referred to as acids, as well as most batteries.
348.2 Mailability

   1. *International Mail*. All corrosives are prohibited.
   2. *Domestic Mail.* A corrosive that can qualify as an air-eligible
   mailable limited quantity is permitted via air (or ground) transportation.
   An ORM-D material that can be renamed with the proper shipping name,
   “Consumer Commodity”, is permitted via surface transportation only.
   Mailable corrosives are also subject to the following:
      1. A liquid mixture must be 1 pint (16 oz) or less and must contain
      15 percent or less corrosive material, with the remainder of the mixture
      not being a hazardous material, unless otherwise specified in 348.22
      <http://pe.usps.com/text/pub52/pub52c3_026.htm#ep900018> for a
      specific corrosive material.
      2. A solid mixture must be 10 pounds or less per primary receptacle
      and must contain 10 percent or less corrosive material, with the
remainder
      of the mixture not being a hazardous material, unless otherwise specified
      for a specific corrosive solid.

348.21 Nonmailable Corrosives

Nonmailable corrosives include the following:

   1. *Batteries* (UN2794, UN2795) with liquid electrolyte (such as
   automobile lead acid batteries), except for the nonspillable type allowed
   under 348.22 <http://pe.usps.com/text/pub52/pub52c3_026.htm#ep900018>.
   2. *Nitric Acid *(UN2031, UN2032).
   3. *Fuming and Spent Sulfuric Acids* (UN1831, UN1832).
   4. *Hydrofluoric Acid *(UN1790).
   5. Except as provided in 348.22
   <http://pe.usps.com/text/pub52/pub52c3_026.htm#ep900018>g
   <http://pe.usps.com/text/pub52/pub52c3_026.htm#ep1028018>, mercury, and
   items containing mercury, including thermometers.

348.22 Mailable Corrosives

As a rule, liquid corrosives are limited to 15 percent solution or less as
stated in 348.2 <http://pe.usps.com/text/pub52/pub52c3_026.htm#ep899984>,
unless otherwise specified below. Mailable corrosives include the following:
- *Acetic Acid* (UN2790). Acceptable in solutions that qualify as mailable
limited quantity material, or an ORM-D material (for surface only), and
contain less than 80 percent acid and do not exceed 1 pint. Packaging
Instruction 8A must be followed.
- *Batteries.* Mailable batteries include:
- Common household dry-cell batteries such as sizes AA, AAA, C, D, etc. are
generally not regulated as hazardous materials and are therefore mailable. For
nickel-metal hydride batteries in sea transportation, see 49 CFR 122.102,
Special Provision 130. Packaging requirements in DMM 601.1-7 apply
-
49 CFR 122.102, Special Provision 130 link:
https://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol2/pdf/CFR-2011-title49-vol2-sec172-102.pdf
, page 333

Bottomline for your purposes seems to be section 348.2a above.

Sincerely,
Dennis B. Swaney

"I think, therefore I Mac"

On Tue, Apr 25, 2017 at 3:10 PM, NewtonTalk <newtontalk at pda-soft.de> wrote:

> Hi friends,
>
> today I got an eMate back that I sent to Ermin more than a month ago. It
> seems that it has spent the last four weeks at some international hub in
> Frankfurt until someone decided that it could not be shipped to the US
> because there are postal restrictions regarding shipments of items that
> contain batteries. There was a sticker on the box that showed some
> batteries
> and the text "UN3481".
>
> Now I am familiar with UN3481. It outlines postal restrictions when it
> comes
> to shipping Lithium-Ion batteries packed with equipment. But to the best of
> my knowledge it does not apply to Nickel-Metal-Hydride batteries packed
> with
> an eMate.
>
> If I wouldn't utterly despise assumptions because they have this annoying
> tendency of wasting lots of my time if they are wrong, I would assume that
> some overzealous clerk made the wrong assumption that everything with a
> keyboard is a laptop and that every laptop is powered by a Li-Ion battery.
> It is beyond me why it took them more than a month to make this assumption,
> but that is another story.
>
> However, before I raise hell at the post office, I would rather get my
> facts
> straight. Obviously shipping Nickel-Metal-Hydride cells in Germany isn't a
> problem, otherwise I wouldn't be able to order the cells I use for battery
> rebuilds. So if there IS a problem with this type of cells, it must be a
> problem with USPS postal services. I would be highly astonished if that was
> the case since I've been shipping Newtons, eMates and rebuilt batteries
> worldwide for the last 16 years, but maybe something has changed in the US.
>
> Since I am not very good at legal stuff in a foreign language, I would ask
> you guys kindly to provide me with any proof that shipment of hardware
> containing Nickel-Metal-Hydride batteries via USPS is either allowed or not
> allowed in the USA. If this has in fact changed in the last couple of
> weeks,
> it would be the end of battery rebuilds from yours truly unless you live in
> Germany, and the end of sales of Newtons or eMates with rebuilt batteries.
>
> Thanks a lot in advance
>
> Frank
>
> -- Newton software and hardware at http://www.pda-soft.de
>
>
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