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Interpretation Response #04-0076 ([ECHO Incorporated] [Mr. Keith Petropoulos])

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

Interpretation Response Details

Response Publish Date:

Company Name: ECHO Incorporated

Individual Name: Mr. Keith Petropoulos

Location State: IL Country: US

View the Interpretation Document

Response text:

Apr 6, 2004

 

Mr. Keith Petropoulos                Reference No. 04-0076

ECHO Incorporated

400 Oakwood Road

Lake Zurich, Il 60047-1564

Dear Mr. Petropoulos:

This is in response to your letter and subsequent phone conversation with Ben Supko of my staff concerning the regulation of outdoor equipment containing small two-cycle engines under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

You state that before these products are shipped they are tested by starting the engines using a fuel line directly inserted into the carburetor, bypassing the fuel tank.  After confirmation that the engine works, the fuel line is closed and engine runs until all the fuel is consumed and the engine stops.  At this point, the primer bulb is pumped while pulling the starting cord to force any residual fuel and vapors from the engine.  It is your belief that this method of emptying and purging the small two-­cycle engine of hazardous materials meets the requirements for being considered empty under § 173.220(a)(1).

An engine may be considered empty if the fuel tank, lines and engine components have been drained, sufficiently cleaned of residue, and purged of vapors to remove any potential hazard.  While it is the responsibility of the shipper to properly classify their materials for transportation, it is the opinion of this Office that the methods you employ sufficiently clean and purge the engines and removes any potential hazards, thus meeting the requirements in § 173.220(a)(1) to be considered empty.

I hope this satisfies your request.

Sincerely,

 

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

173.220(a) (1)

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