Interpretation Response #26-0014
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Beehive Industries
Individual Name: Jessica Humphrey
Location State: CO Country: US
View the Interpretation Document
Response text:
April 29, 2026
Jessica Humphrey
Transportation and Logistics Lead
Beehive Industries
795 S. Potomac Street
Suite 100
Centennial, CO 80112
Reference No. 26-0014
Dear Ms. Humphrey:
This letter is in response to your January 23, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous materials installed in equipment. Specifically, you describe a 0.3L Department of Transportation (DOT) specification cylinder containing methane that is installed in a jet engine.
We have paraphrased and answered your questions as follows:
Q1. Is the DOT specification cylinder considered the "packaging" for the purposes of the HMR, and does the jet engine with the methane tank installed qualify for the exceptions in § 173.220?
A1. While the cylinder is a DOT specification packaging, when attached to the jet engine, the entire apparatus constitutes the packaging, not the cylinder alone. Based on the description provided in your incoming email, the jet engine would qualify for the exceptions in § 173.220.
Q2. Is any additional approval or DOT Special Permit required to ship the jet engine with the methane tank installed?
A2. No. Provided the tank and jet engine properly qualify for exceptions under § 173.220, no further approval or Special Permit would be required.
Q3. Are there any additional packaging approval or design requirements imposed on the jet engine due to the presence of the methane tank?
A3. No. See A2.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.220