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Interpretation Response #17-0039 ([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:

August 14, 2017

Stan Harrison
Team Leader
Williams International
280 E. West Maple Road
Commerce Township, MI 48390

Reference No. 17-0039

Dear Mr. Harrison:

This letter is in response to your April 5, 2017, 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 ask if your company is still permitted to ship engines domestically using the shipping description "UN3166, Engines, internal combustion, flammable liquid powered, Class 9" now that the UN3166 identification number has been designated for "vehicles only" as listed in the Hazardous Materials Table (HMT) in § 172.101.

The answer is yes until January 1, 2018. The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule on March 30, 2017 [(HM-215N); 82 FR 15796] that amended the HMT entry for UN3166 by limiting its applicability to vehicles only. The final rule added three new HMT entries to communicate the type and quantity of fuel present within an engine: UN3528, engines and machinery powered by a flammable liquid; UN3529, engines and machinery powered by flammable gas; and UN3530, Class 9 hazardous materials. The final rule went into effect March 30, 2017, with a delayed compliance date of January 1, 2018. Beginning January 1, 2018, engines powered by a flammable liquid will no longer be eligible for description and classification under "UN3166, Class 9" but must be described and classed as "UN3528, Engine, internal combustion, flammable liquid powered, Class 3." However, note that PHMSA has maintained the existing transportation requirements and exceptions for engines and machinery found in § 173.220 for all modes of transportation, other than vessel, regardless of the description and classification changes.

Therefore, based on the information you have provided and in accordance with the changes adopted in the HMR under the HM-215N final rule, your company is still permitted to ship engines under the shipping description "UN3166, Engines, internal combustion, flammable liquid powered, Class 9" until the delayed compliance date. After the compliance date has passed, it will be the shipper's responsibility to properly classify and describe material based on the new entries in the HMT for internal combustion engines. Items containing other hazardous materials that are integral components of an internal combustion engine may be excepted from the regulations provided the provisions in § 173.220(f)(1) are met.

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



Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.101, 173.220, 173.220(f)(1)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery