Interpretation Response #12-0076 ([Hazardous Control Inc.] [Ms. Nina Ximena Artime])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hazardous Control Inc.
Individual Name: Ms. Nina Ximena Artime
Location State: FL Country: US
View the Interpretation Document
Response text:
July 17, 2012
Ms. Nina Ximena Artime
Hazardous Control Inc.
8600 NW 72 Street
Miami, FL 33166
Ref. No. 12-0076
Dear Ms. Artime:
This responds to your March 20, 2012 request for clarification regarding the transportation by vessel of compressed oxygen under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you are required to package cylinders containing "UN 1072, Oxygen, compressed, 2.2, 5.1" in an outer package that meets the "DOT31FP" specification.
The answer to your question is no. In accordance with §§ 173.302(f) and 173.304(f) compressed oxygen and oxidizing gases transported by aircraft must meet certain requirements. Specifically, these requirements include placing the cylinder in a rigid outer packaging meeting the requirements of §§ 173.302(f)(3) and 173.304(f)(3) respectively. The requirements in §§ 173.302(f) and 173.304(f) are applicable to shipment of compressed oxygen by aircraft, not by vessel.
I hope this answers your inquiry. If you need further assistance, please contact this office at (202) 366-8553.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
173.302(f)