Transportation of a Battery Powered Pallet Jack as Operator Equipment
Pipeline and Hazardous Materials Safety Administration · Dec 5, 2012 · Reference No. 12-0200
Interprets: 49 CFR § 175.8
Reggie’s quick take
A company that moves cargo by air asked whether shipping papers are needed when an electric battery-powered pallet jack is carried on the plane. The pallet jack is used to load pallets onto the aircraft and then travels with it. PHMSA's answer is that the item may fall under the § 175.8(a)(2) exception for hazardous materials required aboard an aircraft under FAA rules. If it does not, § 173.220 governs battery-powered equipment shipped by air, and shipping papers are still required for that equipment.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your September 05, 2012 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You present a scenario in which you utilize an electric battery- powered pallet jack to move pallets from the door of the aircraft to their assigned position on the aircraft. The pallet jack then travels with the aircraft and is utilized to move pallets back to the door for offload at destination. Finally the pallet jack returns with the aircraft to its final destination. You ask if shipping papers are required for the movement of this pallet jack.
As specified in § 175.8(a)(2), hazardous materials required aboard an aircraft in accordance with the applicable Federal Aviation Administration (FAA) airworthiness requirements and operating regulations are excepted from the requirements of the HMR. If the pallet jack is not eligible for the exception in § 175.8(a)(2) requirements for transporting battery- powered equipment for transportation by aircraft are found in § 173.220. Various exceptions are also provided in § 173.220(h). It should be noted that shipping papers are not excepted for battery- powered machinery when offered for transport by aircraft.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.