Interpretation Response #08-0164 ([Labconco Corporation] [Mr. Daniel Taylor])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Labconco Corporation
Individual Name: Mr. Daniel Taylor
Location State: MO Country: US
View the Interpretation Document
Response text:
January 3, 2009
Mr. Daniel Taylor
Product Engineer
Labconco Corporation
8811 Prospect Avenue
Kansas City, MO 64132-2696
Ref. No. 08-0164
Dear Mr. Taylor:
This responds to your letter regarding the proper classification and exceptions for hazardous materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a refrigerating machine that contains a small amount of non-flammable, non-toxic refrigerants (Division 2.2 gases R507 and R508B) and pentane (a Class 3 flammable liquid) under pressure is subject to the HMR. You state that the largest refrigerating machine you intend to offer for transportation contains 195 g of R508B, 18.7 g of pentane and 580 mL of non-hazardous refrigeration oil in one of its two stages.
Under § 173.307(a)(4)(i), a refrigerating machine is not subject to the HMR if it contains 12 kg (25 pounds) or less of a Division 2.2 gas. The gas mixture you describe appears to meet the definition of a Division 2.2 gas as defined in § 173.115(b) and, thus, the refrigerating machine is not subject to the HMR provided it contained less than 12 kg (25 pounds) of the gas.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and reinvention
Office of Hazardous Materials Standards
173.307(a)(4)(i), 173.115(b)
Regulation Sections
| Section | Subject |
|---|---|
| 173.307 | Exceptions for compressed gases |