Interpretation Response #07-0064 ([The Alpha Group] [Mr. Vince Panunzio])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Alpha Group
Individual Name: Mr. Vince Panunzio
Location State: GA Country: US
View the Interpretation Document
Response text:
Jul 9, 2007
Mr. Vince Panunzio Reference No. 07-0064
Materials Manager-
Atlanta Facilities
The Alpha Group
GBE Enterprises!
Alpha Industrial Power
1075 Satellite Blvd Ste. 400
Suwanee, GA 30024
Dear Mr. Panunzio:
This responds to your letter regarding the regulatory requirements and exceptions provided for internal combustion engines under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The engines are transported by highway and are used to generate power in the event of a power outage. Your questions are paraphrased and answered as follows:
Q1. Are our generators subject to the requirements of § 173.220?
Al. Yes.
Q2. If our generators are subject to and conform to the requirements of § 173.220, are they excepted from any additional requirements of the HMR provided they are not transported in a fueled condition?
A2. Regardless of whether the generators are transported in a fueled condition, provided they conform to the conditions specified in § 173.220, as applicable, they are excepted from any additional requirements of the HMR when transported by motor vehicle or rail car.
Q3. What additional requirements, if any, would apply to the transportation of our generators by aircraft?
A3. Your generators "would be excepted from the marking, labeling, placarding, and emergency response telephone number requirements of Part 172 of the HMR.
However, they are subject to all other applicable requirements of the HMR, such as shipping papers, emergency response information, and general packaging requirements.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.220