Interpretation Response #09-0197 ([Tennant Company] [Mr. Charlie Brandenberg])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Tennant Company
Individual Name: Mr. Charlie Brandenberg
Location State: MN Country: US
View the Interpretation Document
Response text:
November 3, 2009
Mr. Charlie Brandenberg
Corporate Safety/Environmental Specialist
Tennant Company
701 North Lilac Drive
Minneapolis, MN 55422
Ref. No.: 09-0197
Dear Mr. Brandenberg:
This responds to your letter dated August 20, 2009, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of walk-behind floor scrubbers powered by lithium-ion batteries. Specifically, you ask if your walk-behind floor scrubbers powered by lithium batteries are considered "mechanical equipment" as the term is used in § 173.220(d), and therefore fall within the purview of § 173.220 as "Battery-powered equipment" as opposed to § 173.185 as "Lithium batteries, contained in equipment."
The answer is yes. Your mechanically operated walk-behind floor scrubbers powered by lithium-ion batteries are appropriately classed as "Battery-powered equipment, UN3171" under the HMR. Therefore, the equipment is subject to § 173.220(d) as mechanical equipment powered by a lithium ion battery. Note that § 173.220(d) forbids the transportation of these devices on passenger carrying aircraft when the battery is installed. Further, the lithium batteries contained in these devices must be of a type that has successfully passed each test in the UN Manual of Tests and Criteria as specified in § 173.185.
I hope this answers your inquiry.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.220, 173.185