Hissong Kenworth-GMC, Inc. — Hazardous Materials Safety Interpretation

Page 12 U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. JUL 13 2007 Mr. Jeff Reutter Manager - Sales Administration/Marketing Ref. No. 06-0265 Hissong Kenworth-GMC, Inc. 2890 Brecksville Rd. P.O. Box 457 Richfield, OH 44286 Dear Mr. Reutter: This responds to your November 27, 2006 letter requesting clarification on what constitutes a "cargo heater" under § 177.834(I)(1) of the Hazardous Materials Regulations (49 CFR Parts 171-180). refrigeration unit installed on an insulated van body mounted on a truck chassis. The According to your letter, your question relates to a diesel powered mechanical refrigeration unit is a split condenser/evaporator design with the diesel engine and condenser installed on the exterior and the evaporator installed on the interior of the insulated van body. System capabilities can maintain temperatures inside the insulated van body from -20 degrees to +85 degrees Fahrenheit. The refrigeration unit uses the adjust temperature inside the insulated van body or to activate or inactivate the truck chassis fuel tanks for its fuel source. There are in-cab controls to monitor and "cargo heater." refrigeration unit. You ask if a mechanical refrigeration unit as described constitutes a vehicle equipped with a cargo heater of any type may transport Class 1 (explosive) Section 177.834(l)(1) states that when transporting Class 1 (explosive) materials, a motor cargo heater fuel tank; and (ii) disconnecting the heater's power source. Based on your materials only if the cargo heater is rendered inoperable by: (i) draining or removing the description and supporting product specifications and photograph, it is the opinion of this Office that your mechanical refrigeration unit does not constitute a "cargo heater" as that term is used in § 177.834(1)(1) of the HMR. I hope this answers your inquiry. /Office of Hazardous Materials Standards Chief, Standards Development 177.834(1) 060265#

Page 2Boothe • $177.834 A KENWORTH Definitions 2890 Brecksville Rd. Hissong Kenworth - GMC, Inc. .O. Box 457 MEDIUM DUTY TRUCKS GMC 06-0265 Richfield, OH 44286 November 27, 2006 Mr. Edward T. Mazzullo U.S. DOT/PHMSA (PHH-10) Director, Office of Hazardous Materials Standards 400 7th Street S.W. Washington, D.C. 20590-0001 Dear Mr Mazzullo, Please clarify the following regulation under CFR 49 Title 177.834: (1) When transporting Class 1 (explosive) materials. A motor vehicle equipped with a heater is rendered inoperable by: (i) Draining or removing the cargo heater fuel tank; and cargo heater of any type may transport Class 1 (explosive) materials only if the cargo (ii) disconnecting the heater's power source. insulated van body mounted on a truck chassis. The refrigeration unit is a split Application involves a diesel powered mechanical refrigeration unit installed on an condenser / evaporator design with the diesel engine and condenser installed on the exterior and the evaporator installed on the interior of the insulated van body. System +85 degrees Fahrenheit. The refrigeration unit uses the truck chassis fuel tanks for its capabilities can maintain temperatures inside the insulated van body from -20 degrees to fuel source. There are in cab controls to monitor and adjust temperature inside the insulated van body or to activate or inactivate the refrigeration unit. does the regulation refer to a combustion or catalytic type heater only? Does a mechanical refrigeration unit as described above constitute a "cargo heater" or for your assistance. If you need additional information, please contact me at your convenience. Thank you Respectfully, Hissong Kenworth - GMC, Inc. Manager - Sales Administration/Marketing Ph: 800-362-7490 Fax: 330-659-4481 Cell: 330-714-5464 Richfield (330) 659-4123 - Watts (800) 362-7490 - Fax (330)-659-4481 Franchised Dealer of Kenworth Trucks and GMC Medium-Duty Trucks#