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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #14-0071 ([Willaims International] [Mr. Stan Harrison])

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

Interpretation Response Details

Response Publish Date:

Company Name: Willaims International

Individual Name: Mr. Stan Harrison

Location State: MI Country: US

View the Interpretation Document

Response text:

November 13, 2014

Stan Harrison
Team Leader
Williams International
Walled Lake Warehousing/Transportation
2280 E. West Maple Road
Commerce Township, MI 48390

Ref. No.: 14-0071

Dear Mr. Harrison:

This is in response to your letter dated April 2, 2014 requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an engine with an installed Class 1 component. The installed component is classed as "UN0325, Igniter, 1.4G" and assigned the Department of Transportation (DOT) approval number EX-2005010294. Specifically, you ask if the basic description "UN3166, Engine, internal combustion, flammable liquid powered, Class 9" is appropriate and ask for confirmation that the engine with installed igniter would be eligible for the provisions of § 173.220(f)(1) as the igniter is both an integral component of the engine and required for operation of the engine. In addition, you note that § 173.220(h)(1) exempts engines from placarding requirements when transported domestically by ground and request clarification on the required hazard communication for international air transport of this engine.

Under §173.56(i) of the HMR, the Associate Administrator for Hazardous Materials Safety may specify a classification or except an explosive material from the requirements of the HMR. In the scenario described, the AA has determined that a 1.4G igniter that is an integral part of the combustion engine does not pose a hazard requiring an approval and may be excepted if the requirements of § 173.220(f)(1) are met. Provided the 1.4G igniter is an integral component of the engine and necessary for the operation of the engine in accordance with § 173.220(f)(1), the basic description "UN3166, Engine, internal combustion, flammable liquid powered, Class 9" would be appropriate. This decision is limited to the facts you presented in your letter.

The requirements of the HMR apply to all modes of transportation. For domestic transportation to the airport of departure by motor vehicle or rail car, provided the fuel tank is securely closed, the engine is not subject to any other requirements under the HMR (e.g., shipping papers, labeling, marking, placarding, or emergency response information). Subpart C of Part 171, authorizes the use of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (TI) if any portion of the transportation is by aircraft. Under the ICAO TI, Packing Instruction 950 provides that dangerous goods required for the operation of the vehicle, machine, or equipment must be securely mounted to the vehicle, machine, or equipment, and in addition requires that dangerous goods identified in Table 3-1 as forbidden on passenger aircraft, only be transported on cargo aircraft. Special Provision A87 excepts articles, which are not fully enclosed by packaging, crates or other means that prevent ready identification, from the marking requirements of 5;2 and the labeling requirements of 5;3.

Please note that this letter of interpretation is based on the information provided specific to the scenario in question and should not be construed to be generally applicable. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

173.220(f)(1), 173.220(h)(1)

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