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 #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.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

173.220, 173.185

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