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Interpretation Response #13-0162 ([Deere & Company WW Supply Management Compliance] [Mr. Mike Moetsch])

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

Interpretation Response Details

Response Publish Date:

Company Name: Deere & Company WW Supply Management Compliance

Individual Name: Mr. Mike Moetsch

Location State: IL Country: US

View the Interpretation Document

Response text:

October 18, 2013

Mr. Mike Moetsch
Manager DG/HM Transportation & Phytosanitary Measures
Deere & Company WW Supply Management Compliance
3400 80th Street
Moline, IL 61265

Reference No.: 13-0162

Dear Mr. Moetsch

This is in response to your August 6, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of tow behind agricultural equipment or machinery containing lead acid batteries but not containing an internal combustion engine or electric motor for propulsion or power source.  You state that these batteries are required to provide additional power in instances when the power unit does not have sufficient electrical power and also function as a back-up power source to prevent accidental shutdown during operations.  Specifically, you ask if this equipment could be classed as “UN3171, Battery-powered equipment” and whether the provisions of
§ 173.220(c) would apply to this equipment or machinery.   

The answer is yes.  The entry “UN3171, Battery-powered equipment” applies to the transportation of battery-powered machinery and equipment equipped with a wet battery (including a non-spillable battery), a sodium battery or a lithium battery.  Requirements for transporting machinery or equipment containing a wet electric storage battery (e.g., lead acid batteries) 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. When transported by rail, highway, or vessel, shipments conforming to the requirements in § 173.220(c) are not subject to the requirements of the HMR except for those described in § 173.21.  When transported by aircraft, shipments conforming to the requirements in § 173.220(c) are excepted from marking, labeling, placarding, and emergency response telephone number requirements as provided in § 173.220(h)(2), however, all other applicable requirements of the HMR apply, including shipping papers and emergency response information, notification of pilot-in-command, general packaging requirements, and the requirements specified in § 173.27.

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


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