Packaging and shipping regulations
Legal requirements
Shipping of lead is regulated by federal law under Title 40 and 49 of the Code of Federal Regulations. Relevant sections are excerpted here. Please reference the full regulations for complete information.
40 CFR Part 273 Universal Waste Exemption
Provides relief from RCRA Subtitle C hazardous waste regulations for the generation, collection, and handling of certain, defined wastes. Wastes eligible for management as universal wastes under the federal rules include batteries (including lead-acid batteries), certain unused pesticides, and mercury-containing items such as thermostats or spent lamps. At the discretion of the regulated party, these wastes may be regulated under 40 CFR Part 273 instead of Parts 260 to 272.
49 CFR Part 173.159 Shipping Requirements
Discusses shipping requirements for wet lead-acid batteries. Includes protecting against short circuits and firmly securing the batteries to skids or pallets capable of withstanding the shocks normal to transportation. The prevention of short circuits is normally accomplished by placing cardboard between the layers of batteries and avoiding steel banding. Do not use styrofoam as separation material because it creates process problems.
Securing batteries to skids can involve an adequate wrapping of shrinkwrap (the wrap should go down far enough to include the skid itself), plastic banding, or a combination of the two. Other methods include plastic bathtubs, heavy-duty cardboard boxes and drums. Short-circuiting and securing requirements apply to all methods.
Ship batteries upright to prevent leaks. Contain any leakers to capture the liquids. If stacking on skids, stack either two or three high. Stacking higher increases the chances of shifting during transit. Take weight limits into account when determining how high to stack and how the load will be distributed in the trailer.
49 CFR Parts 392 & 393 Securement, Blocking and Bracing Standards
Covers protecting against shifting and falling cargo. The easiest method to meet this rule is to avoid large open spaces by loading pallets two wide. In addition, shoring is needed at the back of the load. Nail 2x4's behind the last pallets, or use a load lock bar, or use empty pallets. Shoring also is required in front of the load if the front containers are not snug at the front of the trailer. Many methods can satisfy the rule, and transporters have their own preferred method.
Helpful links
- Minnesota Department of Transportation Hazardous Materials Page
- US Environmental Protection Agency 40 CFR Table of Contents
- US Department of Transportation 49 CFR Table of Contents
- 49 CFR Part 392
- 49 CFR Part 392.9 Safe Loading
- 49 CFR Part 393
- 49 CFR Part 393.100 General Rules
- 49 CFR Part 393.102 Securement Systems
- 49 CFR Part 393.104 Blocking and Bracing
- Minnesota Pollution Control Agency Recycling Hazardous Waste-Feedstocks, By-Products and Sludge (88K PDF)
- Shipping Methods (1,000K PDF)
Proper packaging methods
This information is provided to our customers as a helpful resource and does not replace state and federal requirements. The customer is responsible for ensuring that shipments comply with all applicable state and federal regulations for transporting hazardous materials.
