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Interpretation Response #16-0023 ([Williams 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: Williams International

Individual Name: Mr. Stan Harrison

Location State: MI Country: US

View the Interpretation Document

Response text:

September 27, 2016

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

Reference No. 16-0023

Dear Mr. Harrison:

This letter is in response to your January 18, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an internal combustion engine with installed Class 1 components.  Specifically, you state that the installed components are classed as two “UN0325, Igniter, 1.4G” and one “UN0275, Cartridge, Power Device Installed” and assigned the Department of Transportation (DOT) approval number EX-2005010294 and EX-2008010116, respectively.  Your questions have been paraphrased and answered as follows:

Q1. You ask if the basic description “UN3166, Engine, internal combustion, flammable liquid powered, Class 9” is appropriate and for confirmation that the engine with two installed igniters and one cartridge, power device would be eligible for the provisions of § 173.220(f)(1), as they are integral components of the engine and required for its operation.  

A1.   Under § 173.56(i), 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 you described, the Associate Administrator has determined that a 1.4G igniter and a cartridge, power device that are integral parts of the combustion engine do not pose a hazard requiring an approval and may be excepted if the requirements of § 173.220(f)(1) are met.  Provided the two 1.4G igniters and one cartridge, power device are integral 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.  Please note that this opinion is limited to the facts you presented in your letter.  

Q2. You note that § 173.220(h)(1) exempts engines from placarding requirements when transported domestically by ground, and you request clarification on the required hazard communication for international air transport of this engine.

A2. The requirements for the transportation of engines can vary by mode.  The modal exceptions are provided in § 173.220(b)(4).

Please note that this letter of interpretation is based on the information provided specific to the scenario in question and should not be construed as generally applicable.

I hope this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

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

173.220(f)(1), 173.56(i), 173.220(h)(1), 173.220(b)(4)

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
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery
173.56 New explosives-definition and procedures for classification and approval