PHMSA letter of interpretation

Battery Related Incidents

Pipeline and Hazardous Materials Safety Administration · Sep 1, 1999 · Reference No. 99-0195

PHMSA says to use caution with this letter.

Reggie’s quick take

Someone asked PHMSA for battery-related loss histories, an assessment of battery loss risk, and guidance on shipping battery-operated devices. PHMSA said it cannot provide loss history for battery incidents across all modes. Carriers do not have to report battery-related releases under § 171.16(c)(ii), so no data is collected on them. For wheelchairs with wet electric storage batteries, § 173.222 excepts them from most HMR rules, except § 175.10(a)(19) and (20) for air transport. Even so, § 173.21(c) bars devices likely to spark or generate dangerous heat, so the batteries must be protected from short circuits.

Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.

This is in response to your letter dated July 16, 1999, requesting information on loss histories and assessment information on battery-operated devices, and advice for the proper transportation of batteries and battery-operated devices under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for information on the loss history for battery-related incidents while in any mode of transportation, this Office's assessment of loss potential for battery-related incidents, and guidance on proper methods of transporting battery-operated devices.

Unfortunately, this Office cannot provide you with specific information on the loss history for battery related incidents in all modes of transportation. Section 171.16(a) requires a carrier who transports hazardous materials to report each incident that involves a release of hazardous materials from a package in writing to the Department on DOT Form 5800.1 within 30 days of the discovery. However, § 171.16(c)(ii) excepts electric storage batteries from this reporting requirement. Because data is not collected on battery incidents, we cannot provide you with an assessment of the potential for loss caused by batteries in all modes of transportation. Data collected on other incidents reported under the requirements of § 171.16 can be accessed via the Internet from the following website: http://hazmat.dot.gov/ohmforms.htrn#incidents.

Regarding your request for guidance on transporting batteries, § 173.222 of the HMR excepts wheelchairs equipped with wet electric storage batteries from all requirements of the HMR other than the provisions of § 175.10 (a)(19) and (20), which apply to transportation by aircraft. However, § 173.21(c) forbids the transportation of electrical devices which are likely to generate sparks or adangerous quantity of heat. Therefore, although not directly regulated for transportation, care must be taken when transporting wheelchairs that contain batteries in order to prevent the batteries from short circuiting.

A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.