（A question on UN2800 Battery wet, non-spillable.）
Q.
We plan to ship UN2800 Battery, wet, non-spillable to America. In checking the DGR, we found difficulty in understanding what State Variation USG-11 was saying. USG-11 reads: “A nonspillable wet electric storage battery may only be regarded as not subject to these Regulations if the battery and its outer packaging are plainly and durably marked “NONSPILLABLE” or “NONSPILLABLE BATTERY” and the battery meets the conditions for being regarded as not subject to these Regulations contained in Special Provision A67.” Does the requirement mentioned in USG-11 which reads “and the battery meets the conditions for being regarded as not subject to these Regulations contained in Special Provision A67” mean only when A67 is not satisfied, USG-11 becomes applicable and the Non-Spillable mark would be needed?
The manufacturer’s SDS indicates A67. Can this be interpreted to satisfy that the battery is Not Restricted, and it does not have to be shipped as DG (UN2800). The shipment does not have to use PI872 packagings. We were under the impression that the Non-Spillable mark was required even if A67 conditions were met. Please clarify. (31 Jan 21)
A.
USG-11 states if all the conditions listed in SP A67 are met, thus satisfying the criteria for being regarded as Not Restricted, the package be marked ”NONSPILLABLE” or ”NONSPILLABLE BATTERY” and the shipment will move as Not Restricted.
SP A67 states, Wet cell battery must satisfy the provisions of Vibration test and Pressure differential test to be regarded as Not Restricted. Non-spillable battery must satisfy the various conditions mentioned in SP A67 to be regarded as Not Restricted.
First of all, you need to confirm all the conditions spelled out in SP A67 are met. If affirmative, you need to follow the requirements of USG-11 and ship the battery as Not Restricted. The conditions spelled out in SP A67 is to determine the battery as not subject to the Regulations. Please do not misinterpret.
Furthermore, the entry of the word SP A67 on the SDS does not necessarily mean that conditions of SP A67 has been met. The entry of the word may only be for simple reference. You must confirm that all the conditions of SP A67 have been met to handle the shipment as Not Restricted. UN specification packagings are not required but a strong packaging suitable for air carriage must be used.
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