Are Engines Classified as Dangerous Goods?
Compliance Reminder: The requirements for “draining” fuel differ across various regulations:
- The concept of “draining” in TDG/IMDG:
(1) Liquid fuel: As long as the amount of liquid fuel is insufficient to operate the engine or machinery, it is considered drained. There’s no need to clean or purify the pipes, filters, nozzles, or fuel tanks.
(2) Gaseous fuel: If there’s no liquid in the liquefied gas fuel tank, the tank’s internal pressure does not exceed 2 bar, and the fuel shut-off or isolation valve is closed and secured, the fuel is considered drained. - The concept of “draining” in IATA-DGR:
Engines or machinery are considered drained if they have never had fuel loaded, or the fuel tanks have been cleaned and vapor has been removed. From this, we can deduce that for air transport, if a company wishes to request exemption as general cargo, the fuel must be thoroughly cleared from the fuel tanks; otherwise, it will be treated as dangerous goods.
The core of it lies in whether there is any liquid (fuel), the size of the engine, and whether there’s a battery. When accepting such goods, you should need to know and ask a few questions, and make an initial judgment before proceeding to the next steps. Do not rush to send the goods into the warehouse.
Determining whether an engine qualifies as dangerous goods can generally be deduced when you first see the cargo, provided that there’s no fuel. Usually, all engines undergo fuel testing before leaving the factory. If there’s fuel, it must be drained and cleaned, or left for a sufficient period so that it meets the testing standards.
Below are three test reports:
Should pay attention to the framed sections in the identification reports, those are the common test contents—fuel tank, engine, battery, liquid, fuel lines, and magnetic testing. So just keep an eye on these areas.
When determining if an engine is classified as dangerous goods, consider a few factors, including its size, contents, and the mode of transport.
Here are the main considerations for determining if an engine is dangerous goods:
Fuel or liquid inside the engine:
If the engine contains flammable liquids such as gasoline, diesel, or oil, it would be classified as dangerous goods because these liquids pose a risk of fire or explosion during transport.
Empty engines, if they’ve been drained of flammable liquids, may not be classified as dangerous goods, but specific regulations for transporting “residual hazardous materials” must still be followed.
Size and danger:
The size and power of the engine don’t directly affect whether it’s classified as dangerous goods, but larger engines usually hold more fuel or liquids, increasing the likelihood of being classified as dangerous goods.
For larger engines, it’s also necessary to consider packaging, safety, and stability during transport to prevent leaks or other risks.
Battery-powered engines:
If the engine is powered by a lithium battery, the battery itself may be classified as dangerous goods, meaning the entire engine would fall under the dangerous goods category for shipping.
International transport regulations:
According to the International Maritime Dangerous Goods (IMDG) Code and International Air Transport Association Dangerous Goods Regulations (IATA-DGR), whether an engine is classified as dangerous goods depends on the type and amount of liquid inside it. Even if the engine is drained, any remaining liquid may still require special handling.
One more thing to look for
- Refer to the Safety Data Sheet (SDS): The SDS lists the liquids and other potentially hazardous substances contained in the engine and describes the relevant transportation precautions.
