Interpretation Response #07-0073 ([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:
Jun 4, 2007
Mr. Vince Panunzio Reference No. 07-0073
Materials Manager " Atlanta Facilities
The Alpha Group
GBE Enterprises/Alpha Industrial Power
1075 Satellite Boulevard, Suite 400
Suwanee, GA 30024
Dear Mr. Panunzio:
This responds to your April 5, 2007 e-mail concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of a generator containing an internal combustion engine fueled by either liquefied petroleum gas or natural gas and containing a spillable wet electric storage battery filled with acid. Specifically, you ask whether the requirements in § 173.220 apply to such transportation.
The answer is yes. Section 173.220 applies to the transportation of mechanized equipment containing an internal combustion engine if the engine or fuel tank contains a liquid or gaseous fuel. Section 173.220 also applies to the transportation of mechanized equipment containing a wet electric storage battery, other than a non-spillable battery, or a sodium or lithium battery.
Requirements for transporting mechanized equipment containing an internal combustion engine fueled by either flammable liquefied or compressed gas are set forth in § 173.220(b)(2). Shipments conforming to the requirements in § 173.220(b)(2) are not subject to any other HMR requirements when transported by motor vehicle or railcar and are excepted from marking, labeling, placarding, and emergency response telephone number requirements when transported by vessel or aircraft (see § 173.220(g)). Additional exceptions for shipments by vessel are in § 176.905. Note that if the fuel tank, engine components, and fuel lines are completely drained, cleaned of residue, and purged of vapors to remove any potential hazard, the requirements in § 173.220 do not apply.
Requirements for transporting mechanized equipment containing a wet electric storage battery are set forth in § 173.220(c). The battery must be securely installed, fastened in an upright position, and protected against short circuits and leakage. Shipments conforming to the requirements in § 173.2:20(c) are not subject to any other HMR requirements when transported by motor vehicle or railcar and are excepted from marking, labeling, placarding, and emergency response telephone number requirements when transported by vessel or aircraft see § 173.220(g)). For vessel or air transportation, all other applicable HMR requirements apply, including shipping papers and emergency response information. Additional exceptions for shipments by vessel are in § 176.905.
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.220