{"operation":"document","citation":"26-0014","title":"Beehive Industries — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-04-29","effective_on":null,"summary":"26-0014 response to Beehive Industries concerning 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-26-0014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-26-0014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-26-0014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-04/26-0014.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nApril 29, 2026\nJessica Humphrey\nTransportation and Logistics Lead\nBeehive Industries\n795 S. Potomac Street\nSuite 100\nCentennial, CO 80112\nReference No. 26-0014\nDear Ms. Humphrey:\nThis letter is in response to your January 23, 2026 email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous\nmaterials installed in equipment. Specifically, you describe a 0.3L Department of\nTransportation (DOT) specification cylinder containing methane that is installed in a jet\nengine.\nWe have paraphrased and answered your questions as follows:\nQ1. Is the DOT specification cylinder considered the “packaging” for the purposes of the\nHMR, and does the jet engine with the methane tank installed qualify for the\nexceptions in § 173.220?\nA1. While the cylinder is a DOT specification packaging, when attached to the jet engine,\nthe entire apparatus constitutes the packaging, not the cylinder alone. Based on the\ndescription provided in your incoming email, the jet engine would qualify for the\nexceptions in § 173.220.\nQ2. Is any additional approval or DOT Special Permit required to ship the jet engine with\nthe methane tank installed?\nA2. No. Provided the tank and jet engine properly qualify for exceptions under § 173.220,\nno further approval or Special Permit would be required.\nQ3. Are there any additional packaging approval or design requirements imposed on the\njet engine due to the presence of the methane tank?\n1200 New Jersey Avenue, SE\nWashington, DC 20590\n\n<<>>\n\nA3. No. See A2.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nAlexander Wolcott\nActing Chief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\nJacobson, N.\n26-0014\nFrom: INFOCNTR (PHMSA)\nTo: Hazmat Interps\nSubject: FW: Request for Letter of Interpretation\nDate: Monday, January 26, 2026 3:12:40 PM\nAttachments: image001.png\nHello,\nSee below request for letter of interpretation.\nThanks,\nJonathon\nFrom: Jessica Humphrey \nSent: Friday, January 23, 2026 5:33 PM\nTo: INFOCNTR (PHMSA) \nSubject: Request for Letter of Interpretation\nYou don't often get email from jessica.humphrey@beehiveind.com. Learn why this is important\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nDear PHMSA Hazmat Information Center,\nI am requesting a formal letter of interpretation regarding the application of the\nHazardous Materials Regulations to a jet engine that incorporates a methane cylinder.\nOur company is planning to ship jet engines (approximately 9 inches in diameter and 30\npounds fully assembled) that have a 0.3-liter methane tank installed for functional use.\nThe methane is contained in a DOT-certified cylinder that is manufactured, tested,\nmarked, filled, and maintained in accordance with 49 CFR Parts 173 and 180.\nWe understand that if these engines are shipped by air, the methane cylinder would\nneed to be drained or shipped separately. However, if we ship by ground transportation\nwith the methane tank installed and filled, we are seeking clarification on the following:\n1. Is the DOT-certified cylinder considered the “packaging” for purposes of the HMR\nunder 49 CFR §§171.8, 173.220, and 173.301?\n2. Provided the cylinder complies with all applicable requirements in Parts 173 and\n180, is any separate DOT packaging approval or special permit required for\nshipping the jet engine with the methane tank installed?\n3. Are there any additional sections of the HMR that would impose packaging\n\n<<>>\n\napproval or design requirements on the jet engine due to the presence of the\nmethane tank?\nThese shipments would be offered in commerce by highway.\nThank you for your assistance.\nJessica Humphrey\nTransportation & Logistics Lead\nBeehive Industries\nMobile: 720-583-5595\njessica.humphrey@beehiveind.com\nbeehive-industries.com\n7955 S. Potomac Street\nSuite 100\nCentennial, CO 80112","truncated":false,"body_characters":4215}