Willaims International — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Administration Materials Safety NOV 1 3 2014 Stan Harrison Team Leader Williams International Walled Lake Warehousing/Transportation 2280 E. West Maple Road Commerce Township, MI 48390 Ref. No.: 14-0071 Dear Mr. Harrison: This is in response to your letter dated April 2, 2014 requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an engine with an installed Class 1 component. The installed component is classed as "UN0325, Igniter, 1.4G" and assigned the Department of Transportation (DOT) approval number EX-2005010294. Specifically, you ask if the basic description "UN3166, Engine, internal combustion, flammable liquid powered, Class 9" is appropriate and ask for confirmation that the engine with installed igniter would be eligible for the provisions of § 173.220(F)(1) as the igniter is both an integral component of the engine and required for operation of the engine. In addition, you note that § 173.220(h)(1) exempts engines from placarding requirements when transported domestically by ground and request clarification on the required hazard communication for international air transport of this engine. Under §173.56(i) of the HMR, the Associate Administrator for Hazardous Materials Safety may specify a classification or except an explosive material from the requirements of the HMR. In the scenario described, the AA has determined that a 1.4G igniter that is an integral part of the combustion engine does not pose a hazard requiring an approval and may be excepted if the requirements of § 173.220(f)(1) are met. Provided the 1.4G igniter is an integral component of the engine and necessary for the operation of the engine in accordance with § 173.220(f)(1), the basic description "UN3166, Engine, internal combustion, flammable liquid powered, Class 9" would be appropriate. This decision is limited to the facts you presented in your letter. The requirements of the HMR apply to all modes of transportation. For domestic transportation to the airport of departure by motor vehicle or rail car, provided the fuel tank is securely closed, the engine is not subject to any other requirements under the HMR (e.g., shipping papers, labeling, marking, placarding, or emergency response information). Subpart C of Part 171, authorizes the use of the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (TI) if any portion of the transportation is by aircraft. Under the ICAO TI, Packing Instruction 950 provides that dangerous goods required for the operation#

Page 2of the vehicle, machine, or equipment must be securely mounted to the vehicle, machine, or equipment, and in addition requires that dangerous goods identified in Table 3-1 as forbidden on passenger aircraft, only be transported on cargo aircraft. Special Provision A87 excepts articles, which are not fully enclosed by packaging, crates or other means that prevent ready identification, from the marking requirements of 5;2 and the labeling requirements of 5;3. Please note that this letter of interpretation is based on the information provided specific to the scenario in question and should not be construed to be generally applicable. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, show Chag Shane C. Kelley Acting International Standards Coordinator Standards and Rulemaking Division#

Page 3Wiener Drakeford, Carolyn (PHMSA) § 173.220(f) Sent: From: INFOCNTR (PHMSA) Subject: To: Wednesday, April 02, 2014 5:39 PM Applicabiliti 173.220(f)(1) & (h)(1) Drakeford, Carolyn (PHMSA) 4.0077 Hi Carolyn, please submit this as a formal letter of interpretation to a PHH-13 (Int'I) specialist. Thanks, From: SHarrison@williams-int.com [mailto:SHarrison@williams-int.com] To: INFOCNTR (PHMSA) Sent: Wednesday, April 02, 2014 11:47 AM Subject: 173.220(f)(1) & (h)(1) This is an obtain to receive a certification \letter of Clarification for the classification for this shipment? UN3166 with a UNO325 installed. Please help with providing information for International shipments that we Williams International will be sending to Norway. Shipment: UN3166 Class 9 Engine, internal combustion, flammable liquid powered. On this engine is fixed and installed, grounded and shielded a UN0325, Igniter 1.4G (REFERENCE NUMBER EX2005010294) which is a fixed component required for the operation of the engine. placarding rules, when shipped by ground in the US and prepared in accordance with 49 CFR 173.220. Per 49 CFR 173.220(h)(1), internal combustion engines are not subject to the Hazardous Materials Regulations, including With respect to the Pyro Igniters, see 49 CFR 173.220(f)(1): "Items containing hazardous materials... that are integral components of the motor vehicle, engine, or mechanical equipment and are necessary for the operation of the vehicle, items are not otherwise subject to the requirements of this subchapter." engine, or mechanical equipment.. must be security installed in the motor vehicle, engine, or mechanical equipment. Such Per IATA UN3166 Packing instruction 950(d)(1)(2): Other operational equipment - This dangerous good UN0325, Igniter 1.4G would not be required to be reported on the Dangerous Goods Documents and this International shipment would be shipped as a UN3166 Class 9 Engine, Internal Combustion, Flammable Liquid Powered. Please advise. Stan Harrison Williams Int'l Team Leader Walled Lake Warehousing/Transportation 248-960-2472#