USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #02-0120 ([URS Corporation] [Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

Oct 18, 2002

Mr. Andrew N. Romach                   Reference No. 02-0120

URS Corporation

1600 Perimeter Park Drive

Morrisville, NC 27560

Dear Mr. Rornach:

This responds to your letter regarding an internal combustion engine containing residual flammable liquids, 'such as gasoline or aviation fuel, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) that is transported as Cargo on a transport vehicle.  Your questions are paraphrased and answered as follows:

Q1. We offer, for transportation by motor vehicle, internal combustion engines containing residual flammable liquid fuel in quantities of less than 500 mL(17 ounces) in accordance with § 173.220(b)(1). Are we eligible for the exceptions provided under § 173.220(e)(1)?

A1. The answer is yes.  Except for other hazardous materials specified in § 173.220(d)(2), internal combustion engines shipped under the provisions of § 173.220 are not subject to any additional requirements of the HMR when transported on a transport vehicle.

Q2. Can an internal combustion engine be defined as "mechanical equipment" under the modal exceptions in 9 173.220(b)(4) and, therefore, contain a quantity of flammable liquid fuel greater than 500 mL (17 ounces)?

A2. The answer is no.  Only mechanical equipment and self-propelled vehicles may be offered for transportation containing a quantity of fuel greater than.500 mL (17 ounces).  Mechanical equipment or apparatus will normally contain a fuel tank, a battery, or both, of which an internal combustion engine will be an integral part.

Q3. The engines we offer for transportation are very large and, with the fuel tanks removed, the fuel lines contain residual fuel that cannot be drained to a quantity of 500 mL (17 ounces) or below.  How may an internal combustion engine be described and classed for transportation on a transport vehicle if it does not meet the definition of "mechanical equipment" under the context of § 173.220(b)(4)?

A3. An internal combustion engine with fuel lines containing more than 500 mL of residual flammable liquid fuel in Packing Group II, such as gasoline, must be offered for transportation in UN standard packaging based on the description and hazard class of the fuel itself, or under the terms of a DOT exemption.

In a telephone conversation with Mr. Michael Stevens of my staff you also posed a scenario where the internal fuel capacity of an aviation turbine engine was determined to be less than 450 liters (119 gallons) and the engine contained residual flammable liquid fuel (> 500 mL) with a flash point above 38 EC (100 EF).  You inquired whether the engine may be excepted from the HMR under the combustible liquid in non-bulk packaging provisions in § 173.150(f)(2).

The answer is yes.  A flammable with a flash point between 38 EC (100 EF) and 60.5 EC (141 EF) that does not meet the definition of any other hazard class may be reclassed as a combustible liquid when offered for transportation by motor vehicle.  A combustible liquid in a non-bulk packaging may be excepted from the requirements of the HMR under the conditions specified in § 173.150(f).

I trust this satisfies your inquiry.  Please contact us if we -can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

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