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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.



John A. Gale

Chief, Standards Development

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