Interpretation Response #02-0057 ([Wegman, Hessler & Vanderburg] [John J. Geffer])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Wegman, Hessler & Vanderburg
Individual Name: John J. Geffer
Location State: OH Country: US
View the Interpretation Document
Response text:
February 28, 2002
Mr. John J. Geffert Reference No. 02-0057
Wegman, Hessler & Vanderburg
6055 Rockside Woods Blvd.
Cleveland, Ohio 44131-2302
Dear Mr. Geffert:
This is in response to your letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the term "securely closed" in § 173.220(b)(1). You state that your client wishes to transport a subcompact tractor that has a vented cap on the fuel tank. The vented cap contains a valve that seals off the tank to prevent leakage of fuel in the event the tractor does not remain upright during transportation. You ask whether a vented cap with a sealing valve is considered securely closed under the HMR.
Section 173.220(b)(1) and (b)(4) provides the requirements for transporting self-propelled vehicles containing flammable fuel. The term "securely closed," as it applies to the vents in the cap, means that no flammable gas, vapor or liquid will be able to escape. Securely closing the cap of the fuel tank without also securing vents in the cap does not satisfy the requirement in § 173.220. .
Sections 173.21(g) and 173.24 (f) and (g) also apply to the vented caps on the subcompact tractor. Section 173.21(g) prohibits the offering for transportation or the transportation of packagings that give off a flammable gas or vapor likely to create a flammable mixture with air in a transport vehicle. Section 173.24(f) requires closures on packagings to be secure and leakproof with no release of hazardous materials to the environment from the opening. Section 173.24(g) permits venting to reduce internal pressure only under certain conditions, including when the evolved gases are not likely to
create a flammable mixture with air under normal conditions of transportation. Thus, vents in a cap such as you describe must be securely closed to prevent the escape of gas or vapor.
I hope this information is helpful. Please contact this office if you need additional information.
Sincerely,
Susan E. Gorsky
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.220