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Interpretation Response #08-0045 ([Kubota Manufacturing of America] [Mr. Brian Arnold])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kubota Manufacturing of America

Individual Name: Mr. Brian Arnold

Location State: GA Country: US

View the Interpretation Document

Response text:

March 28, 2008



Mr. Brian Arnold

Kubota Manufacturing of America

2715 Ramsey Road

Gainesville, GA 30501

Reference No. 08-0045

Dear Mr. Arnold:

This is in response to your e-mail transmission requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the shipment of utility vehicles with gasoline fuel systems. You state that you will be transporting utility vehicles with fully closed and sealed gasoline fuel systems with non-vented caps via tractor trailer or rail car and that the fuel systems will contain less than 500 mL (17 ounces) of gasoline. You ask us to confirm your understanding of the HMR that § 173.220(b)(1) authorizes the fuel tank, engine components or fuel lines to contain up to 500 mL of gasoline provided they are securely closed to prevent leakage of fuel during transportation. You also ask us to confirm your understanding that § 173.220(b)(4)(i) authorizes more than 500 mL of gasoline for self-propelled vehicles and mechanical equipment being transported by motor vehicle or rail car provided the fuel tanks are securely closed.

You are correct in your understanding of § 173.220(b)(1) and (b)(4)(i). In addition to the fuel system being securely closed in a manner to prevent leakage of fuel during transportation, any batteries must conform to the applicable conditions in § 173.220. Provided there are no other hazardous materials, except for those that are integral to the vehicle or for safety reasons must be securely installed in the vehicle (see § 173.220(e)), utility vehicles that meet the applicable provisions in § 173.220 are not subject to any other requirements under the HMR (see § 173.220(g)) when transported by motor vehicle or rail car.

I hope this information is helpful. Please contact this office if you have additional questions.



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