The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an April 29th interpretive letter the application of the federal Hazardous Materials Regulations (“HMR”) applicable to hazardous materials installed in equipment. See Reference No. 26-0014.
PHMSA was responding to a January 23rd request for clarification from Beehive Industries (“BI”).
BI described a 0.3L Department of Transportation (“DOT”) specification cylinder containing methane that is installed in a jet engine.
BI first asked whether the DOT specification cylinder is considered “packaging” for the purposes of the HMR, and does the jet engine with the methane tank installed qualify for the exceptions in § 173.220.
PHMSA responds that while the cylinder is a DOT specification packaging, when attached to the jet engine, the entire apparatus constitutes the packaging, not the cylinder alone. Therefore, based on the description BI provided, the jet engine would qualify for the exceptions in § 173.220.
BI then asked whether any additional approval or DOT Special Permit is required to ship the jet engine with the methane tank installed?
PHMSA responds in the negative, stating that provided the tank and jet engine properly qualify for exceptions under § 173.220, no further approval or Special Permit would be required.
BI finally asked whether there are any additional packaging approval or design requirements imposed on the jet engine due to the presence of the methane tank?
PHMSA responds in the negative, citing their answer to the second question.
A copy of the interpretive letter can be found here.
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