Williams International — Hazardous Materials Safety Interpretation

Page 1Transportatic .S. Departmer 1200 New Jersey Avenue, se Washington, D.C. 20590 Pipeline and Hazardous Administration Materials Safety SEP 2 7 2016 Mr. Stan Harrison Team Leader Williams International Walled Lake Warehousing/Transportation 2280 East West Maple Road Commerce Township, MI 48390 Reference No. 16-0024 Dear Mr. Harrison: This letter is in response to your January 18, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an internal combustion engine with installed Class 1 components. Specifically, you state that the installed components are classed as "UN0325, Igniter, 1.4G" and "UN0275, Cartridge, Power Device Installed" and assigned the Department of Transportation (DOT) approval number EX-2005010294 and EX-2008010116, respectively. Your questions have been paraphrased and answered as follows: Q1. You ask if the basic description "UN3166, Engine, internal combustion, flammable liquid powered, Class 9" is appropriate and for confirmation that the engine with an installed igniter and a cartridge, power device would be eligible for the provisions of § 173.220(f)(1), as they are both an integral component of the engine and required for its operation. Al. Under § 173.56(i), 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 you described, the Associate Administrator has determined that a 1.4G igniter and a cartridge, power device that are integral parts of the combustion engine do 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 and cartridge, power device are integral 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. Please note that this opinion is limited to the facts you presented in your letter. Q2. You note that § 173.220(h)(1) exempts engines from placarding requirements when transported domestically by ground, and you request clarification on the required hazard communication for international air transport of this engine.#

Page 2A2. The requirements for the transportation of engines can vary by mode. The modal exceptions are provided in § 173.220(b)(4). Please note that this letter of interpretation is based on the information provided specific to the scenario in question and should not be construed as generally applicable. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, senatosta T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standard and Rulemaking Division#

Page 3Andrews 173.220 Goodall, Shante CTR (PHMSA) Class a From: Geller, Shelby CTR (PHMSA) 16-0024 Sent: Thursday, January 28, 2016 12:15 PM To: Hazmat Interps Subject: FW: Request for a Formal Letter of Interpretation Attachments: U.S DOT Letter of Interpretation.pdf; EX2008010116 FOR PN 72062 pdf; EX2005010294 FOR PN 77803.pdf Attached is the second request. From: SHarrison@williams-int.com [mailto: SHarrison@williams-int.com] To: INFOCNTR (PHMSA) Sent: Monday, January 18, 2016 9:43 AM Cc: SHarrison@williams-int.com Subject: Request for a Formal Letter of Interpretation Hello, This is to obtain a Formal Letter of Interpretation for the classification of a shipment of a UN3166 Engine, Internal installed. Combustion, Flammable liquid Powered with one UN0325 1.4G Igniter and one UN0275 1.3C Cartridge, Power Device Please help with providing information for this domestic shipment. Shipment: UN3166 Class 9 Engine, internal combustion, flammable liquid powered. On this engine is fixed and installed, grounded and shielded one UN0325, Igniter 1.4G (REFERENCE NUMBER EX2005010294) and one UN0275, Cartridge, Power Device (REFERENCE NUMBER EX2008010116) these are fixed components required for the operation of the engine. including 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, With respect to the Igniter and Cartridge, Power Device, 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, engine, or mechanical equipment.. must be securely requirements of this subchapter." installed in the motor vehicle, engine, or mechanical equipment. Such items are not otherwise subject to the The Igniter and Cartridge, Power Device will be securely installed to the engine. The one Igniter will have a Protective from High Energy Frequency Fields and Electrostatic Discharge while in storage or transporting. The Cartridge will have Fraday Cap-Shorting Device installed to provide a ground path from all connector contacts to ground to prevent actuation a Shunt between the wires preventing any connections and a Shielding Cap attached for storage or transporting these protective devices will not be removed until the engine is installed on vehicle. Per IATA UN3166 Packing instruction 950(d)(1)(2): Other operational equipment These dangerous good UN0325, Igniter 1.4G and UN0275, Cartridge, Power Device would not be required to be reported on the Dangerous Goods Documents and this shipment would be shipped as a UN3166 Class 9 Engine, Internal Combustion, Flammable Liquid Powered. 1#

Page 4• In light of the above information please advise if this shipment can be made using UN3166 Engine, Internal Combustion, Flammable Liquid Powered,9? Please see attachments for additional information. Thank you in advance for help!!!! Stan Harrison Team Leader Walled Lake Warehousing \Transportation Williams International Phone: (248)960-2472 E-mail: sharrison@williams-int.com WILLIAMS INTERNATIONAL THE POWER OF VISION This email message and any attachments) are for the sole use of the intended recipients) and may contain proprietary and/or confidential information which may be privileged or otherwise protected from disclosure. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipients), please contact the sender by reply email and destroy the original message and any copies of the message as well as any attachments) to the original message. This email message does not form a binding contract or contract amendment with the sender, unless it clearly states in writing that it is a contract or contract amendment. 2#

Page 5of Transportation U.S. Department Washington, D.C. 20590 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Administration 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(1)(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 6of 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, sume chag Shane C. Kelley Acting International Standards Coordinator Standards and Rulemaking Division#

Page 7U.S. Department of Transportation 1200 New Jersey Avenue, Southeast East Building, PHH - 32 Pipeline and Hazardous Washington, D.C. 20590 Materials Safety Administration Competent Authority for the United States The US Department of Transportation CLASSIFICATION OF EXPLOSIVES Based upon a request by Pacific Scientific, 3601 Union Road, Hollister, CA, the following items are classed in accordance with Section 173.56, Title 49, Code of Federal Regulations (49 CFR). A copy of your application, all supporting documentation and a copy of this approval must be retained and made available to DOT upon request U.N. PROPER SHIPPING NAME AND NUMBER: Cartridges, power device, UN0275 U.N. CLASSIFICATION CODE: 1.3C EX2008010116 REFERENCE NUMBER PRODUCT DESIGNATION/PART NUMBER P/N 829000-01 DATED: February 15, 2008 Approved by: Tracking No: 2008010171 Page 1 of 1#

Page 8of Transportation U.S. Department 100 Seventh Street s.w. Washington, D.C. 20590 Research and Special Programs The US Department of Transportation Administration Competent Authority for the United States CLASSIFICATION OF EXPLOSIVES Based upon a request by Pacific Scientific, 3601 Union Road, Hollister, CA, the föllowing items are classed in accordance with Section 173.56, Title 49, Code of Federal Regulations (49 CFR). A copy of your application, all supporting documentation and a • copy of this approval must be retained and made available to DOT upon request. Igniters, UN0325 U.N. PROPER SHIPPING NAME AND NUMBER: U.N. CLASSIFICATION CODE: 1.4G EX2005010294 REFERENCE NUMBER PRODUCT DESIGNATION/PART NUMBER 15936-05 NOTES: The following packaging method is assigned: Inner Packaging - Bag, foil, each containing one igniter pre-wrapped in plastic bubble wrap. Outer Packaging - UN 4G fiberboard box, each containing not more than fifty (50) inner packagings. DATED: January 26, 2005 Approved by: /Robert A. McGuire Associate Administrator Hazardous Materials Safety Tracking No: 2005010331 Page 1 of 1#