Interpretation Response #08-0017 ([NRS Logistics] [Mr. David Hiromura])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: NRS Logistics
Individual Name: Mr. David Hiromura
Location State: NY Country: US
View the Interpretation Document
Response text:
February 25, 2008
Mr. David Hiromura
President
NRS Logistics
10 Bank Street Suite 1110
White Plains, NY 10606
Ref. No. 08-0017
Dear Mr. Hiromura:
This responds to your letter regarding the use of cylinders for the packaging of toxic by inhalation liquids under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether DOT 4BA240 cylinders with a water capacity of 47.6 lbs and DOT 4BW225 or 4BW240 cylinders with water capacities ranging from 143 lbs to 1,000 lbs are authorized for Division 6.1, Hazard Zone B liquids under §§ 173.40 and 173.227 of the HMR. In addition, you ask what is considered "sufficient outage" as specified in § 173.40(b) for Hazard Zone A and Hazard Zone B materials.
The answer to your first question is yes. Both non-bulk cylinder specifications are authorized for the materials described in your letter. For your information, a cylinder is considered a bulk packaging only when it has a water capacity greater than 1000 lbs. See § 171.8.
With regard to your second question on "sufficient outage," a shipper or filler must consider the coefficient of thermal expansion for the material to be packaged and limit the fill at room temperature so that it will not expand and the cylinder become liquid full at 55 ºC (131 ºF).
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
173.40, 173.227, 171.8