{"operation":"document","citation":"14-0071","title":"Willaims International — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-11-13","effective_on":null,"summary":"14-0071 response to Willaims International concerning 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0071.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0071.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0071","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140071.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nPipeline and Hazardous\nAdministration\nMaterials Safety\nNOV 1 3 2014\nStan Harrison\nTeam Leader\nWilliams International\nWalled Lake Warehousing/Transportation\n2280 E. West Maple Road\nCommerce Township, MI 48390\nRef. No.: 14-0071\nDear Mr. Harrison:\nThis is in response to your letter dated April 2, 2014 requesting clarification of the\nHazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the\nclassification of an engine with an installed Class 1 component. The installed component is\nclassed as \"UN0325, Igniter, 1.4G\" and assigned the Department of Transportation (DOT)\napproval number EX-2005010294. Specifically, you ask if the basic description \"UN3166,\nEngine, internal combustion, flammable liquid powered, Class 9\" is appropriate and ask for\nconfirmation that the engine with installed igniter would be eligible for the provisions of\n§ 173.220(F)(1) as the igniter is both an integral component of the engine and required for\noperation of the engine. In addition, you note that § 173.220(h)(1) exempts engines from\nplacarding requirements when transported domestically by ground and request clarification\non the required hazard communication for international air transport of this engine.\nUnder §173.56(i) of the HMR, the Associate Administrator for Hazardous Materials Safety\nmay specify a classification or except an explosive material from the requirements of the\nHMR. In the scenario described, the AA has determined that a 1.4G igniter that is an integral\npart of the combustion engine does not pose a hazard requiring an approval and may be\nexcepted if the requirements of § 173.220(f)(1) are met. Provided the 1.4G igniter is an\nintegral component of the engine and necessary for the operation of the engine in accordance\nwith § 173.220(f)(1), the basic description \"UN3166, Engine, internal combustion,\nflammable liquid powered, Class 9\" would be appropriate. This decision is limited to the\nfacts you presented in your letter.\nThe requirements of the HMR apply to all modes of transportation. For domestic\ntransportation to the airport of departure by motor vehicle or rail car, provided the fuel tank\nis securely closed, the engine is not subject to any other requirements under the HMR (e.g.,\nshipping papers, labeling, marking, placarding, or emergency response information). Subpart\nC of Part 171, authorizes the use of the ICAO Technical Instructions for the Safe Transport\nof Dangerous Goods by Air (TI) if any portion of the transportation is by aircraft. Under the\nICAO TI, Packing Instruction 950 provides that dangerous goods required for the operation\n\n<<<PAGE 2>>>\n\nof the vehicle, machine, or equipment must be securely mounted to the vehicle, machine, or\nequipment, and in addition requires that dangerous goods identified in Table 3-1 as forbidden\non passenger aircraft, only be transported on cargo aircraft. Special Provision A87 excepts\narticles, which are not fully enclosed by packaging, crates or other means that prevent ready\nidentification, from the marking requirements of 5;2 and the labeling requirements of 5;3.\nPlease note that this letter of interpretation is based on the information provided specific to\nthe scenario in question and should not be construed to be generally applicable. I hope this\ninformation is helpful. If you have further questions, please do not hesitate to contact this\noffice.\nSincerely,\nshow Chag\nShane C. Kelley\nActing International Standards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nWiener\nDrakeford, Carolyn (PHMSA)\n§ 173.220(f)\nSent:\nFrom:\nINFOCNTR (PHMSA)\nSubject:\nTo:\nWednesday, April 02, 2014 5:39 PM\nApplicabiliti\n173.220(f)(1) & (h)(1)\nDrakeford, Carolyn (PHMSA)\n4.0077\nHi Carolyn, please submit this as a formal letter of interpretation to a PHH-13 (Int'I) specialist.\nThanks,\nFrom: SHarrison@williams-int.com [mailto:SHarrison@williams-int.com]\nTo: INFOCNTR (PHMSA)\nSent: Wednesday, April 02, 2014 11:47 AM\nSubject: 173.220(f)(1) & (h)(1)\nThis is an obtain to receive a certification \\letter of Clarification for the classification for this shipment? UN3166 with a\nUNO325 installed. Please help with providing information for International shipments that we Williams International will\nbe sending to Norway.\nShipment: UN3166 Class 9 Engine, internal combustion, flammable liquid powered. On this engine is fixed and installed,\ngrounded and shielded a UN0325, Igniter 1.4G (REFERENCE NUMBER EX2005010294) which is a fixed component\nrequired for the operation of the engine.\nplacarding rules, when shipped by ground in the US and prepared in accordance with 49 CFR 173.220.\nPer 49 CFR 173.220(h)(1), internal combustion engines are not subject to the Hazardous Materials Regulations, including\nWith respect to the Pyro Igniters, see 49 CFR 173.220(f)(1): \"Items containing hazardous materials... that are integral\ncomponents of the motor vehicle, engine, or mechanical equipment and are necessary for the operation of the vehicle,\nitems are not otherwise subject to the requirements of this subchapter.\"\nengine, or mechanical equipment.. must be security installed in the motor vehicle, engine, or mechanical equipment. Such\nPer IATA UN3166 Packing instruction 950(d)(1)(2): Other operational equipment - This dangerous good UN0325, Igniter\n1.4G would not be required to be reported on the Dangerous Goods Documents and this International shipment would be\nshipped as a UN3166 Class 9 Engine, Internal Combustion, Flammable Liquid Powered.\nPlease advise.\nStan Harrison\nWilliams Int'l\nTeam Leader\nWalled Lake Warehousing/Transportation\n248-960-2472","truncated":false,"body_characters":5663}