Deere & Company WW Supply Management Compliance — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAR 2 5 2013 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Mike Moetsch Manager DG/HM Transportation & Phytosanitary Measures Deere & Company WW Supply Management Compliance 3400 80th Street Moline, IL 61265 Ref. No.: 13-0043 Dear Mr. Moetsch: This is in response to your February 11, 2013 e-mail requesting clarification ofthe requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to fire extinguishers transported with self-propelled vehicles. Specifically, you ask whether a fire extinguisher may be transported in a fiberboard box that is banded to the vehicle and if this would be considered securely attached as required by 173.220(£). The answer to your question is yes. Assuming the vehicles are being transported on another motor vehicle and that the requirements of 173.220(f) are satisfied, a fire extinguisher in fiberboard box attached to the vehicle by banding would be considered securely attached. As prescribed in 173.220(±), fire extinguishers that are integral components ofthe motor vehicle, that are necessary for the operation of the vehicle, or for the safety of its operator or passengers, must be securely installed in the motor vehicle. Such items are not otherwise subject to the requirements of this subchapter. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. - ' ~]?6. Delmer Billings ~ Senior Regulatory Advisor Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) hre ~x1l~ uishets Sent: Monday, February 11, 2013 11 :25 AM To: Drakeford, Carolyn (PHMSA) Subject: FW: Fire Extinguisher Securely Attached Clarification t3 -oo4~ Hi Carolyn, We received the following request for a formal letter of interpretation. Thanks, Victoria From: Moetsch Michael P [mailto:MoetschMichaeiP@JohnDeere.com] Sent: Monday, February 11, 2013 10:46 AM To: INFOCNTR (PHMSA) Cc: Moetsch Michael P; Meierotto Connie Subject: Fire Extinguisher Securely Attached Clarification Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration February 11,2013 Dear Sir/Madam: I am requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180) applicable to fire extinguishers transported with self-propelled vehicles. Per 49 CFR 173.220 (f) the extinguisher must be securely attached. A clarification is requested for the true meaning of securely attached. If a fire extinguisher is placed in a fiberboard carton that is banded to the equipment does this satisfy the intent of securely attached? I have reviewed Letter of Interpretation 09-0041 but it does not clearly state the intent of securely attached. Sincerely, Mike Moetsch Deere 8r. Company WW Supply Management Compliance Manager DG/HM Transportation 8r. Phytosanitary Measures 3400 80th Street, Moline, IL 61265 Phone: 309-765-3552 Cell: 309-716-6025 Fax: 309-749-3958 MoetschMichaeiP@JohnDeere.com CONFIDENTIALITY. This message, including attachments, may be confidential. If you believe the message was sent to you in error, do not read the contents and please reply to the sender that you have received the message in error. If you are not the intended recipient, retention, dissemination, distribution, or copying of the communication is strictly prohibited. Thank you. 1#