Interpretation Response #00-0271 ([ZAG Industries] [Mr. Miki Birnbaum])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ZAG Industries
Individual Name: Mr. Miki Birnbaum
Location State: IL Country: US
View the Interpretation Document
Response text:
October 27, 2000
Mr. Miki Birnbaum Ref. No. 00-0271
ZAG Industries
19 Hamelacha Street
New Industrial Zone
Rosh Hayim 48091
ISRAEL
Dear Mr. Birnbaurn:
This is in response to your September 27, 2000 letter requesting clarification on the requirements for outside packagings for cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if there are testing requirements applicable to outside packagings for the shipment of certain cylinders.
Section 173.301(k) requires that DOT Specification 2P, 2Q, 3E, 3HT, 4BA spherical type, 4D, 4DA, 4DS, 9, 39, 40, and 41 cylinders are shipped in a strong outside packaging that adequately provides protection for the cylinder. Unless the cylinders are equipped with a protective neck collar or neck ring, the outside packaging must provide protection from accidental functioning and damage. A strong outside package is defined by § 171.8 to be the outermost enclosure which provides protection against the unintentional release of its contents under conditions normally encountered in transportation. There are no specific testing requirements for strong outside packagings.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.301