{"operation":"document","citation":"98-0051","title":"HAZMAT and Dangerous Goods Program — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-06-08","effective_on":null,"summary":"98-0051 response to HAZMAT and Dangerous Goods Program concerning 173.220.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0051.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0051.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0051","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980051.pdf","body":"<<<PAGE 1>>>\n\nMemorandum\nU.S. Department\nof Transportation\nResearch and\nSpecial Programs\nAdministration\nDate:\nJN - 8 1998\nReply 10 Aten. of:\nSubjecti\nACTION: Chain of Requires or rema Contusion Engines\nFrom:\nEdward T. Mazzullo, Dire\nOffice of Hazardous Materials Standards\nTo:\nCharles Lovinski, Manager\nHAZMAT and Dangerous Goods Program\nThis is in response to your memo requesting clarification of whether aircraft engines, such as\njet engines, turbine engines, and turbo props being shipped by aircraft are subject to the\nfollows:\nHazardous Matenals Regulations (HMIR). Your questions are paraphrased and answered as\nQuestion 1. Are aircraft engines which are being transported by air that have been\ndrained and purged of all fuel subject to the HMR?\nAircraft engines, whether piston-powered, rotary-powered, or turbine-powered, derive their\npower by hear and pressure produced by the compression and combustion of a fuel-air\nmixture. Therefore, aircraft engines are properly classified as \"Engines, internal combustion,\n9, UN 3166\", and regulated by the provisions of the HMR. An aircraft engine that does not\nontain a hazardous matenal such as flammable liquid, however, is not regulated under the\nprovisions of the HMR. Any method that renders the engine sufficiently cleaned of residue\nand purged of vapors to remove any potential hazard is acceptable.\nQuestion 2. Are aircraft engines which are being transported by air, that have not been\npurged of residual fuel, subject to the HMR? If so, how must the engine be described\nand prepared for shipment?\nA jet engine which contains a hazardous matenai, such as a flammable liquid, is subject to\nine requirements of the HMiR. Section 173.220 (b) provides for the transportation by aircraft\nof an internal combustion engine utilizing flammable liquid fuel with up to 500 ml (17 oz) of\nfuel in engine components provided the lines are securely closed to prevent leakage. Section\n173.220 (g) excepts shipments made under the provisions of this section from part 172,\nsubparts D, E, and F, (marking, labeling, and placarding, respectively) and $ 172.604\n(emerger, cy response telephone number) for transportation by aircraft. All other\nrequirements of the HMR would apply.\nI trust this satisfies your inquiry. If this office can be of further assistance, please contact us.\n#\n\n<<<PAGE 2>>>\n\n•A=g\n•\nNelson\n§173.220\nMemorandum\nU.S. Department\nUsemame\nof Transportation\nACS_FAA\nFederal Avlation\nAdministration\nSubject: ACTION: Engines, internal combustion\nDare: MAY 121998\nFrom: Dangerous Goods and Cargo Security Program, Atta\nB. Romo\nACO-800\n202-267-3207\nto: Edward T. Mazzullo, Director,\nOffice of Hazardous Materials Standards/RSPA\nACO-800 is requesting a letter of clarification on the applicability of the\nHazardous Materials Regulations (HMR) to aircraft engines. Our agents are\nencountering numerous situations involving improperly declared or undeclared\naircraft engines, such as jet engines, turbine engines, and turbo-props. Many\nair carriers are offering and transporting these engines as non-regulated,\nwhether or not the engines have been drained and purged. These carriers\nclaim the shipping description \"Engines, internal combustion, 9, UN 3166\" does\nnot apply to aircraft engines.\nAttached is a memo from our Chicago field office, which describes two ways in\nwhich an aircraft engine can be drained and purged of all fuel. We are\nrequesting your opinion as to whether aircraft engines which have been drained\nand purged in the described manner would be subject to the HMR. In addition,\ndo you consider an aircraft engine which has not been purged (i.e., residual fuel\nremains in the fuel lines, manifolds and fuel controls) to be subject to the HMR\nand, if so, how would this engine be described and prepared for shipment?\nI appreciate your attention to this matter. If you have any questions or need\nadditional assistance, please contact Beth Romo of my staff.\nChat ahe\nMarles N. Lovinsk\nAttachment\n\n<<<PAGE 3>>>\n\nThis space\nis for\npagination\nfor\nand allows\nthe\nmasthead\nSubject: ACTION: Letter of Interpretation,\nDaro: May 1, 1998\nUN3166 Engines, Internal Combustion\nFrom: Manager, Chicago Civil Aviation\nReply to James Berk\nSecurity Field Office\nAten. of;\n(847) 928-8050\nFAX (847) 928-8090\nTo: Regulations Development Office of\nHazardous Materials Standards\nTHRU:Beth Romo, Dangerous\nGoods Staff, ACO-800\nlassification and transportation of aircraft engines (i.e. jet engines, turbine\nhe Chicago CASFO has encountered several problems involving the imprope\nengines, turbo-prop).\nIn general, industry believes aircraft engines are NOT considered Engines,\nInternal Combustion. Most airlines are accepting and shipping these items as\nnon-regulated. This is being accomplished without consideration of whether or\nnot the engine has been drained and PURGED.\nSome common responses received from the carriers are: \"we have been\nshipping aircraft engines the same way for 20 years\", or \"the manufacturer (GE,\nPratt & Whitney) has told us this is NOT UN3166\", or \"173.220 applies to\nvehicles not jet engines.\nThe Chicago CASFO has been advised that aircraft engines are property\nclassified as UN3166 , Engine, Internal Combustion, Class 9.\nAn aircraft engine can be purged or preserved in two ways. A Hot Preservation\nis accomplished at the end of an engine test. Testing facilities will shut of the\nfuel supply and introduce lightweight (1010) oil. The engine continues to run\nburning this oil instead of the fuel. Fuel has now been replaced with oil and the\nflammable liquid has been completely removed. After the engine is shut down, it\ncan be drained of excess oil and preservation should be documented in engine\nrecords.\n\n<<<PAGE 4>>>\n\n-\n2\nEngines removed to be sent back to the repair facility could be cold\npurged/preserved if equipment is available. A hand operated pump filled with the\nsame 1010 oil or preservative will be attached to a specific location on the fuel\ncontrol or tuel pump (directed by manufacturer technical instructions). A fuel line\nor valve will be opened down stream of the manual pump location. Oil will be\npumped through the fuel system until all the fuel has been pushed out and\nreplaced with oil. The excess oil can then be drained and lines resealed.\nDocumentation should once again be noted in the engine records.\nIf an aircraft engine has been drained and PURGED of all fuel (and properly\ndocumented on the engine records), is the shipper required to label, mark, ship\nthe matenal as a hazardous material?\nIf an aircraft engine has not been PURGED (residual fuel remaining in lines,\nhazardous material?\nmanifolds and fuel controls...), is the shipper required to ship the equipment as a\nBased on the ongoing misunderstanding within the aviation industry, please\nprovide a written letter of clarification relative to the proper classification of\naircraft engines for air transportation.\nJoyce B. Scott\nFile:\nWP: C: Wy DocumentsIRequest Letter of Interpretation.doc\nORD CASFO,JBerk,JEB, (847) 928-8010,4/29/98","truncated":false,"body_characters":7002}