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Interpretation Response #98-0051 ([HAZMAT and Dangerous Goods Program] [Charles Lovinski])

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

Interpretation Response Details

Response Publish Date:

Company Name: HAZMAT and Dangerous Goods Program

Individual Name: Charles Lovinski

Location State: DC Country: US

View the Interpretation Document

Response text:

Date:    JUN 8, 1998                     Reply to Attn. of:    Ref. No. 98-0051

Subject:     ACTION: Clarification of Requirements For Internal Combustion Engines

From:    Edward T. Mazzullo

Office of Hazardous Materials Standards

To:    Charles Lovinski, Manager

HAZMAT and Dangerous Goods Program

This is in response to your memo requesting clarification of whether aircraft engines, such as jet engines, turbine engines, and turbo props being shipped by aircraft are subject to the Hazardous Materials Regulations (HMR). Your questions are paraphrased and answered as follows:

Question 1. Are aircraft engines which are being transported by air that have been drained and purged of all fuel subject to the HMR?

Aircraft engines, whether piston-powered, rotary-powered, or turbine-powered, derive their power by heat and pressure produced by the compression and combustion of a fuel-air mixture. Therefore, aircraft engines are properly classified as "Engines, internal combustion, 9, UN 3166" and regulated by the provisions of the HMR. An aircraft engine that does not contain a hazardous material such as flammable liquid, however, is not regulated under the provisions of the HMR. Any method that renders the engine sufficiently cleaned of residue and purged of vapors to move any potential hazard is acceptable.

Question 2. Are aircraft engines which are being transported by air, that have not been purged of residual fuel, subject to the HMR? If so, how must the engine be described and prepared for shipment?

A jet engine which contains a hazardous material, such as a flammable liquid, is subject to the requirements of the HMR Section 173.220 (b) provides for the transportation by aircraft of an internal combustion engine utilizing flammable liquid tire1 with up to 500 ml(17 oz) of fue1 in engine components provided the lines are securely closed to prevent leakage. Section 173.220 (g) excepts shipments made under the provisions of this section from part 172, subparts D, E, and F, (marking, labeling, and placarding, respectively) and § 172.604 (emergency response telephone number) for transportation by aircraft. All other requirements of the HMR would apply.

I trust this satisfies your inquiry. If this office can be of further assistance, please contact us.

#

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