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Interpretation Response #14-0023 ([Kohler Company] [Mr. Michael Major])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kohler Company

Individual Name: Mr. Michael Major

Location State: WI Country: US

View the Interpretation Document

Response text:

September 19, 2014

Mr. Michael Major
Manager – Regulatory Compliance
Kohler Company
444 Highland Drive
Kohler, Wisconsin 53044

Ref. No. 14-0023

Dear Mr. Major:

This responds to your January 30, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to definitions.  Your company builds a propane fueled, towable generator, permanently mounted to a trailer.  The generator’s propane tank is integrated into the unit and supplies propane fuel exclusively for the operation of the unit’s internal combustion engine.  You ask whether the propane tanks meet the definition of a fuel tank as defined in 49 CFR § 171.8.
From your description of the generator unit, the answer is yes.  As defined in 49 CFR § 171.8, a fuel tank means "a tank, other than a cargo tank, used to transport flammable or combustible liquid, or compressed gas for the purpose of supplying fuel for propulsion of the transport vehicle to which it is attached, or for the operation of other equipment on the transport vehicle." Fuel systems that meet the requirements under 49 CFR §§ 393.65 and 393.67 of the Federal Motor Carrier Safety Regulations (FMCSRs) and are not used as packaging for hazardous materials are subject only to the FMCSRs.  As prescribed in 49 CFR § 393.69(a), a fuel system that uses liquefied petroleum gas as a fuel for the operation of a motor vehicle or for the operation of auxiliary equipment installed on, or used in connection with, a motor vehicle must conform to the "Standards for the Storage and Handling of Liquefied Petroleum Gases" of the National Fire Protection Association (NFPA), Battery March Park, Quincy, MA 02269.
I trust this information is helpful.  Please contact us if you require further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations