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Interpretation Response #07-0061 ([LIST Company, Inc.] [Mr. Rob Latham])

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

Interpretation Response Details

Response Publish Date:

Company Name: LIST Company, Inc.

Individual Name: Mr. Rob Latham

Location State: SC Country: US

View the Interpretation Document

Response text:

March 14, 2008

Mr. Rob Latham

LIST Company, Inc.

106 Prosperity Blvd.

Piedmont, SC 29673

Ref. No. 07-0061

Dear Mr. Latham:

This is in response to your letter requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to an electrical generator containing propane installed on commercial trucks. You state that the generator provides power to charge the truck"s batteries and power the electrical system of the truck when the truck"s engine is not running. I apologize for the delay in responding and any inconvenience it may have caused.

A fuel tank meeting the requirements in the Federal Motor Carrier Safety Regulations (FMCSR) for fuel systems and used only for supplying fuel for the operation of a motor vehicle or its auxiliary equipment is not subject to regulation under the HMR with respect to its use on the vehicle. See FMCSR requirements at 49 CFR 393.65, and 393.69 for liquefied petroleum gas systems. Such tanks must conform to all applicable marking requirements and be maintained in accordance with NFPA/ASME standards for fuel systems.

I hope this information is helpful. Please contact this office if you need additional assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.101 173.220

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