{"operation":"document","citation":"17-0039","title":"Williams International — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-08-14","effective_on":null,"summary":"17-0039 response to Williams International concerning 172.101, 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0039.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0039.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0039","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/170039.pdf","body":"<<>>\n\nTeam Leader\nWilliams International\n280 E. West Maple Road\nCommerce Township, MI 48390\nReference No. 17-0039\nDear Mr. Harrison:\nThis letter is in response to your April 5, 2017, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an\ninternal combustion engine with installed Class 1 components. Specifically, you ask if your\ncompany is still permitted to ship engines domestically using the shipping description \"UN3166,\nEngines, internal combustion, flammable liquid powered, Class 9\" now that the UN3166\nidentification number has been designated for \"vehicles only\" as listed in the Hazardous\nMaterials Table (HMT) in § 172.101.\nThe answer is yes until January 1, 2018. The Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) published a final rule on March 30, 2017 [(HM-215N); 82 FR 15796]\nthat amended the HMT entry for UN3166 by limiting its applicability to vehicles only. The final\nrule added three new HMT entries to communicate the type and quantity of fuel present within\nan engine: UN3528, engines and machinery powered by a flammable liquid; UN3529, engines\nand machinery powered by flammable gas; and UN3530, Class 9 hazardous materials. The final\nrule went into effect March 30, 2017, with a delayed compliance date of January 1, 2018.\nBeginning January 1, 2018, engines powered by a flammable liquid will no longer be eligible for\ndescription and classification under \"UN3166, Class 9\" but must be described and classed as\n\"UN3528, Engine, internal combustion, flammable liquid powered, Class 3.\" However, note that\nPHMSA has maintained the existing transportation requirements and exceptions for engines and\nmachinery found in § 173.220 for all modes of transportation, other than vessel, regardless of the\ndescription and classification changes.\nTherefore, based on the information you have provided and in accordance with the changes\nadopted in the HMR under the HM-215N final rule, your company is still permitted to ship\nengines under the shipping description \"UN3166, Engines, internal combustion, flammable\n\n<<>>\n\nSincerely,\nSirk Der Kinderei\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<>>\n\nvalegories.\nCharles\nHi Shante/Alice,\nPlease submit this as a letter of interpretation. Mr. Harrison spoke with Eamonn.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: SHarrison@williams-int.com [mailto:SHarrison@williams-int.com]\nSent: Wednesday, April 05, 2017 11:40 AM\nTo: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov>\nSubject: Hazmat Inquiry\nGood Morning,\nThis is an request for two new Letters of Interpretation (LOI). On received September 2016 Williams\nInternational (WI) received two LOI please see attachments for the original request and LOI.\nWI will provide engines UN3166 Engine, Internal Combustion, Flammable liquid Powered Class 9 with two\nUNO325 1.4G Igniter and a UN0275 1.3C Cartridge, Power Device installed for domestic shipments.\nBased on the information in the IATA 58t edition of Dangerous Goods Regulations at the end of March 2017 all\nentries of \"engines\" were deleted from UN 3166 in Class 9 and now only applies to the proper shipping name\"\nof the fuel that powers the engine.\nvehicles.\" Engines are now assigned to UN 3528 - UN 3530 in Division 2.1, Class 3 or Class 9, based on the classification\nUsing IATA UN3528 will not allow for the shipment of this engine with any explosive's. At this point 49 CFR has not\nharmonized with IATA. January 2018 when 49 CFR harmonize with IATA and all engines are deleted from UN3166 in\nClass 9 will WI based on the LOl attached be allowed to complete our contractual obligation shipping these engines\nusing UN3166 Class 9? Please provide TWO NEW LOI regarding this issue.\nRespectfully,\nStan Harrison\nTeam Leader\nWalled Lake Warehousing Transportation\n\n<<>>\n\ntestaments) are for the sole use of the intended\nrecipients) and may contain proprietary and/or confidential information which may\nbe privileged or otherwise protected from disclosure.\nAny unauthorized review, use, disclosure or distribution is prohibited. If you are\nnot the intended recipients), please contact the sender by reply email and destroy\nthe original message and any copies of the message as well as any attachments)\nto the original message.\nThis email message does not form a binding contract or contract amendment with\nthe sender, unless it clearly states in writing that it is a contract or contract amendment.\n2\n\n<<>>\n\nau. Dial flarrison\nTeam Leader\nWilliams International\nWalled Lake Warehousing/Transportation\n2280 East West Maple Road\nCommerce Township, MI 48390\nReference No. 16-0024\nDear Mr. Harrison:\nThis letter is in response to your January 18, 2016, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the\nclassification of an internal combustion engine with installed Class 1 components.\nSpecifically, you state that the installed components are classed as \"UN0325, Igniter, 1.4G\"\nand \"UN0275, Cartridge, Power Device Installed\" and assigned the Department of\nTransportation (DOT) approval number EX-2005010294 and EX-2008010116, respectively.\nYour questions have been paraphrased and answered as follows:\nQ1.\nYou ask if the basic description \"UN3166, Engine, internal combustion, flammable\nliquid powered, Class 9\" is appropriate and for confirmation that the engine with an\ninstalled igniter and a cartridge, power device would be eligible for the provisions of\nits operation.\n§ 173.220(f)(1), as they are both an integral component of the engine and required for\nAl. Under § 173.56(i), the Associate Administrator for Hazardous Materials Safety may\nspecify a classification or except an explosive material from the requirements of the\nHMR. In the scenario you described, the Associate Administrator has determined that\na 1.4G igniter and a cartridge, power device that are integral parts of the combustion\nengine do not pose a hazard requiring an approval and may be excepted if the\nrequirements of § 173.220(f)(1) are met. Provided the 1.4G igniter and cartridge,\npower device are integral 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. Please note that this\nopinion is limited to the facts you presented in your letter.\nQ2.\nYou note that § 173.220(h)(1) exempts engines from placarding requirements when\ntransported domestically by ground, and you request clarification on the required\nhazard communication for international air transport of this engine.\n\n<<>>\n\nSincerely,\nsantosta\nT. Glenn Foster\n• Chief, Regulatory Review and Reinvention Branch\nStandard and Rulemaking Division\n\n<<>>\n\nAttached is the second request.\nFrom: SHarrison@williams-int.com [mailto:SHarrison@williams-int.com]\nSent: Monday, January 18, 2016 9:43 AM\nTo: INFOCNTR (PHMSA)\nCc: SHarrison@williams-int.com\nSubject: Request for a Formal Letter of Interpretation\nHello,\nThis is to obtain a Formal Letter of Interpretation for the classification of a shipment of a UN3166 Engine, Internal\ninstalled.\nCombustion, Flammable liquid Powered with one UN0325 1.4G Igniter and one UN0275 1.3C Cartridge, Power Device\nPlease help with providing information for this domestic shipment.\nShipment:\nUN3166 Class 9 Engine, internal combustion, flammable liquid powered. On this engine is fixed and installed, grounded\nand shielded one UN0325, Igniter 1.4G (REFERENCE NUMBER EX2005010294) and one UN0275, Cartridge, Power\nDevice (REFERENCE NUMBER EX2008010116) these are fixed components required for the operation of the engine.\nPer 49 CFR 173.220(h)(1), Internal Combustion Engines are not subject to the Hazardous Materials Regulations,\nincluding placarding rules, when shipped by ground in the US and prepared in accordance with 49 CFR 173.220\nWith respect to the Igniter and Cartridge, Power Device, see 49 CFR 173.220(f)(1):\n\"Items containing hazardous materials... that are integral components of the motor vehicle, engine, or mechanical\nequipment and are necessary for the operation of the vehicle, engine, or mechanical equipment.. must be securely\ninstalled in the motor vehicle, engine, or mechanical equipment. Such items are not otherwise subject to the\nrequirements of this subchapter.\"\nThe Igniter and Cartridge, Power Device will be securely installed to the engine. The one Igniter will have a Protective\nFraday Cap-Shorting Device installed to provide a ground path from all connector contacts to ground to prevent actuation\nfrom High Energy Frequency Fields and Electrostatic Discharge while in storage or transporting. The Cartridge will have\na Shunt between the wires preventing any connections and a Shielding Cap attached for storage or transporting these\nprotective devices will not be removed until the engine is installed on vehicle.\nPer IATA UN3166 Packing instruction 950(d)(1)(2): Other operational equipment\nThese dangerous good UN0325, Igniter 1.4G and UN0275, Cartridge, Power Device would not be required to be reported\non the Dangerous Goods Documents and this shipment would be shipped as a UN3166 Class 9 Engine, Internal\nCombustion, Flammable Liquid Powered.\n1\n\n<<>>\n\nwillams international\nPhone: (248)960-2472\nE-mail: sharrison@williams-int.com\nWILLIAMS INTERNATIONAL\nTHE POWER OF VISION\nThis email message and any attachments) are for the sole use of the intended\nrecipients) and may contain proprietary and/or confidential information which may\nbe privileged or otherwise protected from disclosure.\nAny unauthorized review, use, disclosure or distribution is prohibited. If you are\nnot the intended recipients), please contact the sender by reply email and destroy\nthe original message and any copies of the message as well as any attachments)\nto the original message.\nThis email message does not form a binding contract or contract amendment with\nthe sender, unless it clearly states in writing that it is a contract or contract amendment.\n2\n\n<<>>\n\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<<>>\n\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\nchey\nShane C. Kelley\nActing International Standards Coordinator\nStandards and Rulemaking Division\n\n<<>>\n\nBased upon a request by Pacific Scientific, 3601 Union Road, Hollister, CA, the\nUN. PROPER SHIPPING NAME AND NUMBER:\nCartridges, power device, UN0275\nU.N. CLASSIFICATION CODE: 1.3C\nREFERENCE NUMBER\nEX2008010116\nPRODUCT DESIGNATION/PART NUMBER\nP/N 829000-01\nDATED: February 15, 2008\nApproved by:\nManfreetti\nTracking No: 2008010171\nPage 1 of 1\n\n<<>>\n\nAdministration\nCLASSIFICATION OF EXPLOSIVES\nBased upon a request by Pacific Scientific, 3601 Union Road, Hollister, CA, the\nfollowing items are classed in accordance with Section 173.56, Title 49, Code of Federal\nRegulations (49 CFR). A copy of your application, all supporting documentation and a\ncopy of this approyal must be retained and made available to DOT upon request.\nU.N. PROPER SHIPPING NAME AND NUMBER:\ngutters, UN0325\nU.N. CLASSIFICATION CODE: 1.4G\nREFERENCE NUMBER\nEX2005010294\nPRODUCT DESIGNATION/PARE NUMBER\n15936-05\nNOTES:\nThe following packaging method is assigned: Inner Packaging - Bag, foil, each\ncontaining one igniter pre-wrapped in plastic bubble wrap. Outer Packaging - UN 4G\nfiberboard box, each containing not more than fifty (50) inner packagings.\nDATED: January 26, 2005\nApproved by:\ng Robert A. McGuire\nAssociate Administrator\nHazardous Materials:$\nTracking No: 2005010331\nPage 1 of 1\n\n<<>>\n\nWilliams International\nWalled Lake Warehousing/Transportation\n2280 East West Maple Road\nCommerce Township, MI 48390\nReference No. 16-0023\nDear Mr. Harrison:\nThis letter is in response to your January 18, 2016, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the\nclassification of an internal combustion engine with installed Class 1 components.\nSpecifically, you state that the installed components are classed as two \"UN0325, Igniter,\n1.4G\" and one \"UN0275, Cartridge, Power Device Installed\" and assigned the Department of\nTransportation (DOT) approval number EX-2005010294 and EX-2008010116, respectively.\nYour questions have been paraphrased and answered as follows:\nQ1. You ask if the basic description \"UN3166, Engine, internal combustion, flammable\nliquid powered, Class 9\" is appropriate and for confirmation that the engine with two\ninstalled igniters and one cartridge, power device would be eligible for the provisions\nof § 173.220(f)(1), as they are integral components of the engine and required for its\noperation.\nAl. Under § 173.56(i), the Associate Administrator for Hazardous Materials Safety may\nspecify a classification or except an explosive material from the requirements of the\nHMR. In the scenario you described, the Associate Administrator has determined that\na 1.4G igniter and a cartridge, power device that are integral parts of the combustion\nengine do not pose a hazard requiring an approval and may be excepted if the\nrequirements of § 173.220(f)(1) are met. Provided the two 1.4G igniters and one\ncartridge, power device are integral and necessary for the operation of the engine in\naccordance with § 173.220(f)(1), the basic description \"UN3166, Engine, internal\ncombustion, flammable liquid powered, Class 9\" would be appropriate. Please note\nthat this opinion is limited to the facts you presented in your letter.\nQ2.\nYou note that § 173.220(h)(1) exempts engines from placarding requirements when\ntransported domestically by ground, and you request clarification on the required\nhazard communication for international air transport of this engine.\n\n<<>>\n\nSincerely,\nlenn Foster\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandard and Rulemaking Division\n\n<<>>\n\nDear Shante and Alice,\nForwarded is a request for a formal letter of interpretation. I spoke with Mr. Harrison about his request. There is a\nsecond interpretation request which only varies slightly from this request, which I will forward next. I spoke with Aaron\nand he mentioned that they can probably be written in the same letter.\nMr. Harrison's address is:\n2280 East West Maple Road\nWalled Lake Michigan, MI 48390\nThanks,\nShelby\nFrom: SHarrison@williams-int.com [mailto:SHarrison@williams-int.com]\nSent: Monday, January 18, 2016 10:20 AM\nTo: INFOCNTR (PHMSA)\nCc: SHarrison@williams-int.com\nSubject: Request for a Formal Letter of Interpretation with this configuration\nHello,\nThis is to obtain a Formal Letter of Interpretation for the classification of a shipment of a UN3166 Engine, Internal\ninstalled.\nCombustion, Flammable liquid Powered with two UN0325 1.4G Igniter and a UN0275 1.3C Cartridge, Power Device\nPlease help with providing information for this domestic shipment.\nShipment:\nUN3166 Class 9 Engine, internal combustion, flammable liquid powered. On this engine is fixed and installed, grounded\nand shielded two UN0325, Igniter 1.4G (REFERENCE NUMBER EX2005010294) and a UN0275, Cartridge, Power Device\n(REFERENCE NUMBER EX2008010116) these are fixed components required for the operation of the engine.\nPer 49 CFR 173.220(h)(1), Internal Combustion Engines are not subject to the Hazardous Materials Regulations,\nincluding placarding rules, when shipped by ground in the US and prepared in accordance with 49 CFR 173.220.\nWith respect to the Igniter and Cartridge, Power Device, see 49 CFR 173.220(f)(1):\n\"Items containing hazardous materials... that are integral components of the motor vehicle, engine, or mechanical\nequipment and are necessary for the operation of the vehicle, engine, or mechanical equipment.. must be securely\ninstalled in the motor vehicle, engine, or mechanical equipment. Such items are not otherwise subject to the\nrequirements of this subchapter.\"\n1\n\n<<>>\n\nIn light of the above information please advise if this shipment can be made using UN3166 Engine, Internal Combustion,\nFlammable Liquid Powered,9? Please see attachments for additional information.\nThank you in advance for help!!!!\nStan Harrison\nTeam Leader\nWalled Lake Warehousing\\Transportation\nWilliams International\nPhone: (248)960-2472\nE-mail: sharrison@williams-int.com\nWILLIAMS INTERNATIONAL\nTHE POWER OF VISION\nThis email message and any attachments) are for the sole use of the intended\nrecipients) and may contain proprietary and/or confidential information which may\nbe privileged or otherwise protected from disclosure.\nAny unauthorized review, use, disclosure or distribution is prohibited. If you are\nnot the intended recipients), please contact the sender by reply email and destroy\nthe original message and any copies of the message as well as any attachments)\nto the original message.\nThis email message does not form a binding contract or contract amendment with\nthe sender, unless it clearly states in writing that it is a contract or contract amendment.\n2\n\n<<>>\n\nBased upon a request by Pacific Scientific, 3601 Union Road, Hollister, CA, the\nfollowing items are classed in accordance with Section 173.56, Title 49, Code of Federal\nRegulations (49 CFR). A copy of your application, all supporting documentation and a\ncopy of this approval must be retained and made available to DOT upon request.\nU.N. PROPER SHIPPING NAME AND NUMBER:\nCartridges, power device, UN0275\nU.N. CLASSIFICATION CODE: 1.3C\nREFERENCE NUMBER\nEX2008010116\nPRODUCT DESIGNATION/PART NUMBER\nP/N 829000-01\nDATED: February 15, 2008\nApproved by:\nMastrettin\nTracking No: 2008010171\nPage 1 of 1\n\n<<>>\n\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<<>>\n\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 CHay\nShane C. Kelley\nActing International Standards Coordinator\nStandards and Rulemaking Division\n\n<<>>\n\nAdministration\nCLASSIFICATION OF EXPLOSIVES\nBased upon a request by Pacific Scientific, 3601 Union Road, Hollister, CA, the\nfollowing items are classed in accordance with Section 173.56, Title 49, Code of Federal\nRegulations (49 CFR). A copy of your application, all supporting documentation and a\n• copy of this approval must be retained and made available to DOT upon request.\nU.N. PROPER SHIPPING NAME AND NUMBER:\nIgniters, UN0325\nU.N. CLASSIFICATION CODE: 1.4G\nREFERENCE NUMBER\nEX2005010294\nPRODUCT DESIGNATION/PART NUMBER\n15936-05\nNOTES:\nThe following packaging method is assigned: Inner Packaging - Bag, foil, each\ncontaining one igniter pre-wrapped in plastic bubble wrap. Outer Packaging - UN 4G\nfiberboard box, each containing not more than fifty (50) inner packagings.\nDATED: January 26, 2005\nApproved by:\n*Robert A. McGuire\nAssociate Administrator\nHazardous Materials:\nTracking No: 2005010331\nPage 1 of 1\n\n<<>>\n\nHello,\nThis is to obtain a Formal Letter of Interpretation for the classification of a shipment of a UN3166 Engine, Internal\nCombustion, Flammable liquid Powered with two UN0325 1.4G Igniter and a UN0275 1.3C Cartridge, Power Device\ninstalled.\nPlease help with providing information for this domestic shipment.\nShipment:\nUN3166 Class 9 Engine, internal combustion, flammable liquid powered. On this engine is fixed and installed, grounded\nand shielded two_UN0325, Igniter 1.4G (REFERENCE NUMBER EX2005010294) and a UN0275, Cartridge, Power Device\n(REFERENCE NUMBER EX2008010116) these are fixed components required for the operation of the engine.\nPer 49 CFR 173.220(h)(1), Internal Combustion Engines are not subject to the Hazardous Materials Regulations,\nincluding placarding rules, when shipped by ground in the US and prepared in accordance with 49 CFR 173.220.\nWith respect to the Igniter and Cartridge, Power Device, see 49 CFR 173.220(f)(1):\n\"Items containing hazardous materials... that are integral components of the motor vehicle, engine, or mechanical\nequipment and are necessary for the operation of the vehicle, engine, or mechanical equipment. must be securely\ninstalled in the motor vehicle, engine, or mechanical equipment. Such items are not otherwise subject to the\nrequirements of this subchapter.\"\nThe Two Igniter and One Cartridge, Power Device will be securely installed to the engine. The two Igniters will have\nProtective Fraday Cap-Shorting Device installed to provide a ground path from all connector contacts to ground to prevent\nactuation from High Energy Frequency Fields and Electrostatic Discharge while in storage or transporting. The Cartridge\nwill have a Shunt between the wires preventing any connections and a Shielding Cap attached for storage or transporting,\nthese protective devices will not be removed until the engine is installed on vehicle.\nPer IATA UN3166 Packing instruction 950(d)(1)(2): Other operational equipment\nThese dangerous good UNO325, Igniter 1.4G and UN0275, Cartridge, Power Device would not be required to be reported\non the Dangerous Goods Documents and this shipment would be shipped as a UN3166 Class 9 Engine, Internal\nCombustion, Flammable Liquid Powered.\nIn light of the above information please advise if this shipment can be made using UN3166 Engine, Internal Combustion,\nFlammable Liquid Powered,9? Please see attachments for additional information.\nThank you in advance for help!!!!\nStan Harrison\nTeam Leader\n1\n\n<<>>","truncated":false,"body_characters":26618}