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