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Question of the Week
How Do I Ship a Forklift?
Q. I am shipping a warehouse forklift to another facility. The machine runs on a small engine and uses a lead-acid battery. I am not shipping hazardous materials, but a device that contains flammable and corrosive material. How do I prepare the forklift for transportation?

A. You say the forklift is equipment that contains a battery and a fuel engine. The 49 CFR 172.101 Hazardous Materials Table has entries for “Battery Powered Vehicles or Equipment” and “Vehicle, Flammable Liquid Powered.”
| Name |
Class & ID |
Special
Provisions |
Packaging
Instructions |
| Battery-powered vehicle or Battery-powered equipment. |
9 UN3171 |
134 |
220 |
| Vehicle, flammable gas powered. |
9 UN3166 |
135, 157 |
220 |
Vehicle, flammable liquid powered. |
9 UN3166 |
135, 157 |
220 |
Special Provisions 134, 135, and 157 state that a vehicle with an internal combustion engine installed must use the shipping name “Vehicle, Flammable Gas Powered” or “Vehicle, Flammable Liquid Powered” if the machine also contains a battery power source.
The packaging instructions at 49 CFR 173.220 state that when shipped by motor vehicle or rail, shipments of flammable liquid powered vehicles are not subject to any other provisions of the Hazardous Materials Regulations. A vehicle must be prepared using the packing instructions at 49 CFR 173.220 if it meets any of the following requirements: the engine or tank contains flammable fuel (including a residue or vapor of flammable fuel), the machine is equipped with a wet spillable battery, a sodium or lithium battery, or contains other unsecured non-essential hazardous materials.
Before transportation, the fuel tanks of the vehicle must be securely closed. With regards to emptying the fuel tanks and engine system, additional requirements apply for transportation by aircraft or vessel.
Any batteries must be securely installed, and wet batteries must also be fastened in an upright position. Battery terminals must be protected against short circuits and leakage, or removed and packaged separately. Additional requirements apply for lithium batteries as per Special Provision A101.
Any other hazardous materials in the equipment necessary for the operation of the device or the safety of its passengers, for example hydraulic systems of compressed air cylinders, must be securely installed or packaged and transported in accordance with the full hazardous materials regulations.
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DOT & International Transportation News
02/13/2008U.S. DOT Takes Action to Reduce Train Accidents Caused by Human Error, Greater Accountability Placed on Railroad Management and Employees for Safety
Reducing common mistakes that result in nearly half of all human factor-caused train accidents is the aim of a new federal regulation that places greater accountability on both railroad management and employees for complying with basic operating rules, announced U.S. Transportation Secretary Mary E. Peters.
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02/12/2008BLG Sub-Committee Agrees [to] Technical Proposals for Reduction of Air Pollution from Ships
Draft amendments to revise the MARPOL regulations on the prevention of air pollution from ships were agreed by the IMO Sub-Committee on Bulk Liquids and Gases (BLG) when it met last week (4-8 February) for its 12th session. Following lengthy and technically challenging discussions in the Air Pollution Working Group, the Sub-Committee agreed a draft revised Annex VI to the MARPOL Convention and amendments to the NOx Technical Code. These will now be submitted to the Marine Environment Protection Committee (MEPC), which meets for its 57th session from 31 March to 4 April 2008.
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02/12/2008Dangerous Goods Advisory Bulletin: Ethyl Chloride in Aluminum Cylinders
The Federal Aviation Administration (FAA) advises shippers, air carriers, and freight forwarders to avoid transporting Ethyl Chloride (including mixtures) in aluminum cylinders. Recently, an aluminum compressed gas cylinder containing Ethyl Chloride ruptured in an air cargo warehouse in Dubai, U.A.E. The cylinder had traveled by cargo aircraft from Manchester, U.K. The investigation of this incident suggests the possibility that a reaction occurred within the aluminum cylinder as a result of the incompatibility between the Ethyl Chloride gas and the aluminum cylinder.
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02/12/2008Dangerous Goods Agreement Enters into Force
On 31 January 2008, Germany ratified the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN), bringing the number of Contracting Parties to seven. As a result, the ADN will enter into force one month later on 29 February 2008.
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01/31/2008Important Change in International Land and Sea Travel Document Procedures
The U.S. Department of Homeland Security (DHS) reminds the traveling public that U.S. and Canadian citizens ages 19 and older should no longer expect that they will be able to prove identity and citizenship by relying on an oral declaration alone. Instead, travelers will be asked to present documents from one of the options below when entering the United States at land or sea ports of entry. Travelers who do not present one of the documents listed below may be delayed as U.S. Customs and Border Protection officers attempt to verify their identify and citizenship.
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01/31/2008Addendum for the 49th Edition of the IATA Dangerous Goods Regulations
On January 31, 2008 the International Air Transport Association (IATA) published an addendum to the Transport of Dangerous Goods Regulations. Included in this addendum are changes to Operator Variations and packing instruction 910.
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01/15/2008New 2008 Emergency Response Guidebook Coming
Beside being readily available electronically via the PHMSA website, DOT expects that over two million free copies of the upcoming 2008 revised edition of the Emergency Response Guidebook (ERG) will be published and distributed to fire fighters, police and emergency services personnel across the nation. The ERG is an internationally recognized guide designed to aid emergency first responders at the scene of a transportation incident involving hazardous materials. It is DOT's goal to have the ERG readily accessibe in both the electronic and paper format.
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01/15/2008DOT to Address Cargo Tank Rollovers
PHMSA and the Federal Motor Carrier Safety Administration (FMCSA) are working together to develop plans to address cargo tank rollovers. A recently completed “Cargo Tank Roll Stability Study” contracted by FMCSA with Battelle evaluated four complementary approaches to reducing the number of cargo tank truck rollovers: redesigning the vehicle, redesigning the highways, deploying electronic stability aids, and improving the training of drivers.
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Recent DOT Rules, Standards, and Interpretations
For Lion Members and Recent Course Attendees
01/28/2008Hazardous Materials; Miscellaneous Amendments
PHMSA is amending the Hazardous Materials Regulations to update, clarify or provide relief from certain requirements governing the classification, packaging, or labeling of hazardous materials transported in commerce. Among other provisions, PHMSA is adopting a new proper shipping name and identification number for fuel blends composed of ethanol and gasoline.
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