Interpretation Response #22-0135
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Generac Power Systems, Inc.
Individual Name: Steven Charles
Location State: FL Country: US
View the Interpretation Document
Response text:
March 28, 2023
Mr. Steven Charles
Global Transportation Manager
Generac Power Systems, Inc.
245 Lasa Drive, Unit 307
St. Augustine, FL 32084
Reference No. 22-0135
Dear Mr. Charles:
This letter is in response to your December 13, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium ion battery powered ride-on lawn mowers. In your email, you describe a lithium ion battery powered lawn mower commonly referred to as a "zero-turn" mower. Specifically, you ask whether your zero-turn mower may be described as "UN3171, Battery-powered vehicle, 9" and transported under the provisions of § 173.220.
The answer is yes. The entry “UN3171, Battery-powered vehicle or Battery-powered equipment” applies to the transportation of battery-powered machinery and equipment equipped with wet batteries (including non-spillable batteries), sodium batteries, or lithium batteries. Requirements for transporting machinery or equipment containing lithium batteries are specified in § 173.220(c) and (d). As described in § 173.220(c), batteries must be securely fastened in the battery holder of the vehicle, engine, or mechanical equipment, and be protected in such a manner as to prevent damage and short circuits. Battery-powered vehicles, machinery, or equipment including battery-powered wheelchairs and mobility aids are not subject to any other requirements of the HMR—except § 173.21 (Forbidden material and packages)—when transported by rail, highway, or vessel.
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
Standards and Rulemaking Division
173.220(c)