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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 #03-0158 ([Pillsbury Winthrop] [Mr. David M. Hernandez])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pillsbury Winthrop

Individual Name: Mr. David M. Hernandez

Location State: DC Country: US

View the Interpretation Document

Response text:

Jul 10, 2003


Mr. David M. Hernandez               Reference No. 03-0158

Senior Associate

Pillsbury Winthrop

1133 Connecticut Avenue, NW

Washington, DC 20036

Dear Mr. Hernandez:

This responds to your June 24, 2003 letter requesting a clarification, on behalf of Texaco Ovonic Hydrogen Systems, L.L.C., on the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to a motor vehicle powered by hydrogen contained in a metal hydride storage system.  Specifically, you inquired whether your client"s motor vehicle when transported by highway is excepted from all requirements of the HMR as provided in § 173.220(e)(1).

The answer is yes.  The fuel system, the metal hydride storage system containing hydrogen, falls within the exceptions provided in § 173.220(b)(2) and (d)(1).  Therefore, when the fuel system is securely installed and closed during transportation, the motor vehicle is not subject to any other requirements of the HMR as provided in paragraph (e)(1).

I hope this satisfies your inquiry.  If you have further questions, please do not hesitate to contact this office.



Edward T. Mazzullo

Director,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