{"operation":"document","citation":"13-0043","title":"Deere & Company WW Supply Management Compliance — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-03-25","effective_on":null,"summary":"13-0043 response to Deere & Company WW Supply Management Compliance concerning 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0043.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0043.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0043","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130043.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nMAR 2 5 2013\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Mike Moetsch\nManager DG/HM Transportation & Phytosanitary Measures\nDeere & Company WW Supply Management Compliance\n3400 80th Street\nMoline, IL 61265\nRef. No.: 13-0043\nDear Mr. Moetsch:\nThis is in response to your February 11, 2013 e-mail requesting clarification ofthe\nrequirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)\napplicable to fire extinguishers transported with self-propelled vehicles. Specifically, you ask\nwhether a fire extinguisher may be transported in a fiberboard box that is banded to the vehicle\nand if this would be considered securely attached as required by 173.220(£).\nThe answer to your question is yes. Assuming the vehicles are being transported on another\nmotor vehicle and that the requirements of 173.220(f) are satisfied, a fire extinguisher in\nfiberboard box attached to the vehicle by banding would be considered securely attached.\nAs prescribed in 173.220(±), fire extinguishers that are integral components ofthe motor\nvehicle, that are necessary for the operation of the vehicle, or for the safety of its operator or\npassengers, must be securely installed in the motor vehicle. Such items are not otherwise\nsubject to the requirements of this subchapter.\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\n- '\n~]?6.\nDelmer Billings ~\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nINFOCNTR (PHMSA)\nhre ~x1l~ uishets\nSent:\nMonday, February 11, 2013 11 :25 AM\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: Fire Extinguisher Securely Attached Clarification t3 -oo4~\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Moetsch Michael P [mailto:MoetschMichaeiP@JohnDeere.com]\nSent: Monday, February 11, 2013 10:46 AM\nTo: INFOCNTR (PHMSA)\nCc: Moetsch Michael P; Meierotto Connie\nSubject: Fire Extinguisher Securely Attached Clarification\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nFebruary 11,2013\nDear Sir/Madam:\nI am requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180)\napplicable to fire extinguishers transported with self-propelled vehicles. Per 49 CFR 173.220 (f) the extinguisher must be\nsecurely attached.\nA clarification is requested for the true meaning of securely attached. If a fire extinguisher is placed in a fiberboard carton\nthat is banded to the equipment does this satisfy the intent of securely attached?\nI have reviewed Letter of Interpretation 09-0041 but it does not clearly state the intent of securely attached.\nSincerely,\nMike Moetsch\nDeere 8r. Company WW Supply Management Compliance\nManager DG/HM Transportation 8r. Phytosanitary Measures\n3400 80th Street, Moline, IL 61265\nPhone: 309-765-3552\nCell: 309-716-6025\nFax: 309-749-3958\nMoetschMichaeiP@JohnDeere.com\nCONFIDENTIALITY. This message, including attachments, may be confidential. If you believe the message was sent to you in error,\ndo not read the contents and please reply to the sender that you have received the message in error. If you are not the intended\nrecipient, retention, dissemination, distribution, or copying of the communication is strictly prohibited. Thank you.\n1","truncated":false,"body_characters":3484}