Hauling Motor Vehicles Considered Hazmat Load?

That's a really dumb reg, that would mean any flatbed and any tow truck has to have it indicated on their MCS-150 and as suggested in your link the right insurance.

 

So, here's a question:

I have a gasoline powered generator that I use as an APU to run the heat pump installed in my sleeper. Does that mean that I have to comply with this requirement?

 

90% of the regs are dumb. Adding it to the MCS-150 is no big deal - just check a box.

The insurance I had the 1 million already. What is the minimum 750k? I don't really know I have always had 1 million liability.

For me getting compliant was no big deal.Cost me zero and took less than 5 minutes.

I am about 99% sure this is the law and correct but I bet it is not heavily enforced.

I have no idea on your APU generator.

 

No, small quanities of gasoline can be classed as a "material of trade" and are permissible. The larger issue, if a sharp inspector looks at your generator and it is a gravity feed system like most off the shelf one are, that is a clear violation. It must be fed from a tank via a pump to be FMCSA compliant. See below.

There are two regulations you must comply with if you chose to use a portable generator. The first is transporting and storage of fuel for the generator and the second is the fuel delivery system. Carrying gasoline in a small can is fine as long as it is less than 8 gallons, an approved container and properly secured while in motion. The problem for using standard portable generators is the fuel system regulations found in 393.65 (d) which prohibits gravity fed fuel systems on commercial motor vehicles and their auxiliary power systems. You need to find a generator with an electric fuel pump not one with the tank on top that uses gravity to feed it. A typical inverter type gasoline powered generator from Home Depot or Lowes is not going to be compliant, you will need a RV type generator.

§392.51 Reserve fuel; materials of trade.
Small amounts of fuel for the operation or maintenance of a commercial motor vehicle (including its auxiliary equipment) may be designated as materials of trade (see 49 CFR 171.8).

(a) The aggregate gross weight of all materials of trade on a motor vehicle may not exceed 200 kg (440 pounds).

(b) Packaging for gasoline must be made of metal or plastic and conform to requirements of 49 CFR Parts 171, 172, 173, and 178 or requirements of the Occupational Safety and Health Administration contained in 29 CFR 1910.106.

(c) For Packing Group II (including gasoline), Packing Group III (including aviation fuel and fuel oil), or ORM-D, the material is limited to 30 kg (66 pounds) or 30 L (8 gallons).

(d) For diesel fuel, the capacity of the package is limited to 450 L (119 gallons).

(e) A Division 2.1 material in a cylinder is limited to a gross weight of 100 kg (220 pounds). (A Division 2.1 material is a flammable gas, including liquefied petroleum gas, butane, propane, liquefied natural gas, and methane).

§393.65 All fuel systems.
(a) Application of the rules in this section. The rules in this section apply to systems for containing and supplying fuel for the operation of motor vehicles or for the operation of auxiliary equipment installed on, or used in connection with, motor vehicles.

(b) Location. Each fuel system must be located on the motor vehicle so that—

(1) No part of the system extends beyond the widest part of the vehicle;

(2) No part of a fuel tank is forward of the front axle of a power unit;

(3) Fuel spilled vertically from a fuel tank while it is being filled will not contact any part of the exhaust or electrical systems of the vehicle, except the fuel level indicator assembly;

(4) Fill pipe openings are located outside the vehicle's passenger compartment and its cargo compartment;

(5) A fuel line does not extend between a towed vehicle and the vehicle that is towing it while the combination of vehicles is in motion; and

(6) No part of the fuel system of a bus manufactured on or after January 1, 1973, is located within or above the passenger compartment.

(c) Fuel tank installation. Each fuel tank must be securely attached to the motor vehicle in a workmanlike manner.

(d) Gravity or syphon feed prohibited. A fuel system must not supply fuel by gravity or syphon feed directly to the carburetor or injector.

(e) Selection control valve location. If a fuel system includes a selection control valve which is operable by the driver to regulate the flow of fuel from two or more fuel tanks, the valve must be installed so that either—

(1) The driver may operate it while watching the roadway and without leaving his/her driving position; or

(2) The driver must stop the vehicle and leave his/her seat in order to operate the valve.

(f) Fuel lines. A fuel line which is not completely enclosed in a protective housing must not extend more than 2 inches below the fuel tank or its sump. Diesel fuel crossover, return, and withdrawal lines which extend below the bottom of the tank or sump must be protected against damage from impact. Every fuel line must be—

(1) Long enough and flexible enough to accommodate normal movements of the parts to which it is attached without incurring damage; and

(2) Secured against chafing, kinking, or other causes of mechanical damage.

(g) Excess flow valve. When pressure devices are used to force fuel from a fuel tank, a device which prevents the flow of fuel from the fuel tank if the fuel feed line is broken must be installed in the fuel system.

 

So, the small engines that drive the hydraulics on self contained car haulers and RGN trailers don't use gravity feed for the fuel supply?

 

That is a great question that I don't have a answer for yet. I will look into it though. May have something to do with being mounted on the motor vehicle vs. the trailer? I only know the regulations, not the one to make the rules nor do I always understand why. This only came to mind because of a losing case with a client that had a gas powered generator on his tractor and was cited under 393.65(d) by the Pennsylvania State Police.

 

Be sure to verify the words "may" and "will". Make sure the requirement is law and not a you can do it.

 

Drove pulling a Rodgers 'Croucher' low-bed. Standard Briggs and Stratton with gravity fuel system drive the hydraulic pump for the hydraulics on the removable goose-neck.

 

Wait just a second. The people in charge of overseeing our job don't know what there talking about.