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Interpretation Response #19-0123

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

Interpretation Response Details

Response Publish Date:

Company Name: AECOM

Individual Name: Ms. Danielle Heaney

Location State: NC Country: US

View the Interpretation Document

Response text:

April 15, 2020

Ms. Danielle Heaney
Compliance Specialist
AECOM
1600 Perimeter Park
Morrisville, NC 27560

Reference No. 19-0123

Dear Ms. Heaney:

This letter is in response to your October 16, 2019 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171–180) applicable to the proper shipping description for internal combustion engines. Specifically, you seek confirmation that interpretation letters issued under Reference Nos. 04-0249 and 13-0125 pertaining to exceptions to the HMR for a cleaned and purged jet engine with a "spark gap" contained in a securely installed exciter box remain valid, regardless of the changes in proper shipping name and United Nations (UN) number and a more representative hazard class for engines, internal combustion.

The answer is yes. The letters of clarification issued under Reference Nos. 04-0249 and 13-0125 remain valid. The Pipeline and Hazardous Materials Safety Administration (PHMSA) would consider a cleaned and purged jet engine with a "spark gap" contained in a securely installed exciter box to be excepted from the requirements of the HMR, provided the applicable requirements in 49 CFR § 173.220 are met.

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

Sincerely,

T. Glenn Foster
Chief, Standards and Rulemaking Division
Office of Hazardous Material Standards
173.220

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