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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0085 ([West Marine Products] [Mr. Todd Nash])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: West Marine Products

Individual Name: Mr. Todd Nash

Location State: SC Country: US

View the Interpretation Document

Response text:

APR 20, 2001


Mr. Todd Nash                      Ref. No: 01-0085

Hazardous Materials Manager

West Marine Products

860 Marine-Drive

Rock Hill, SC 29730-8089

Dear Mr. Nash:

This is in response to your letter of March 27,2001, requesting clarification of requirements for transporting an internal combustion engine under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if a used outboard engine that does not have internal gas tanks and thus no "cap" that can be securely closed may be transported under the provisions of § 173.220 if it contains less than 17 ounces of fuel. If such an engine were placed on its side or placed upside down there is the potential for fuel to leak out of the engine.

The answer is no. When transported as "Engine, internal combustion, 9, UN3166,1t the engine must meet the packaging provisions of § 173.220. Section 173.220(b)(1) requires a fuel tank containing a flammable liquid fuel to be drained and securely closed. Up to 500 ml (17 ounces) of residual fuel may remain in the tank engine, components, OJ.!" fuel lines provided they are securely closed to prevent leakage of fuel during transportation. The engine you describe has no means of being securely closed and has the potential to leak fuel in certain orientations.

If there is no means to prevent the leakage of fuel, an engine such as you describe must be classed for the fuel contained therein ( e.g., gasoline) and be placed in a packaging that is authorized for its transportation. The alternative is to completely clean and purge the engine; if no gasoline or residue remains in the engine, the HMR do not apply to its transportation.

I hope this information is helpful.



John A. Gale

Transportation Specialist

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery