Interpretation Response #05-0281 ([Shindaiwa, Inc.] [Mr. Dennis Stauch])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Shindaiwa, Inc.
Individual Name: Mr. Dennis Stauch
Location State: OR Country: US
View the Interpretation Document
Response text:
Nov 30, 2005
Mr. Dennis Stauch Reference No. 05-0281
Vice President of Engineering and Manufacturing
Shindaiwa, Inc.
11975 S.W. Herman Road
Tualatin, OR 97062
Dear Mr. Stauch:
This is in response to your letter and subsequent telephone conversation with Ben Supko of my staff concerning the regulation of outdoor power equipment containing two and four cycle single cylinder internal combustion 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 is operating properly, the fuel line is disconnected and the engine runs until all the fuel is consumed and the engine stops. You indicate that this method of emptying and purging the fuel system meets the requirements in § 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 remove 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)(2)