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Interpretation Response #12-0039 ([Caterpillar, Inc.] [Mr. Jerry A. Shipman En])

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

Interpretation Response Details

Response Publish Date:

Company Name: Caterpillar, Inc.

Individual Name: Mr. Jerry A. Shipman En

Location State: IL Country: US

View the Interpretation Document

Response text:

April 11, 2012



Mr. Jerry A. Shipman
Environmental, Safety, and Health Manager
Caterpillar, Inc.
500 N. Morton Ave.
Morton, IL 61550
Reference No.: 12-0039

Dear Mr. Shipman:

This is in response to your January 27, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the classification of generators. Specifically, you ask if generators powered by diesel fuel or gasoline should be classified as UN 3166 Vehicle Flammable Liquid Powered.

The answer is no. While it is ultimately the responsibility of the shipper to properly classify their hazardous materials shipments in accordance with § 173.22(a)(1), it is the opinion of this office that a generator powered by an internal combustion engine is most appropriately classified as either Engines, internal combustion, flammable gas powered or Engines, internal combustion, flammable liquid powered (both UN 3166).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division




Regulation Sections

Section Subject
173.22 Shipper's responsibility