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.
Sincerely,
Edward T. Mazzullo
Director,Office of Hazardous Materials Standards
173.220