USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

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.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

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