Interpretation Response #99-0322 ([Firetrace Systems International, Inc.] [Mr. Len Seebaluck, P.Eng.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Firetrace Systems International, Inc.
Individual Name: Mr. Len Seebaluck, P.Eng.
Country: CA
View the Interpretation Document
Response text:
May 5, 2000
Mr. Len Seebaluck, P.Eng. Ref. No. 99-0322
Engineering Manager
Firetrace Systems International, Inc.
102, 118-1st Avenue
Cochrane, Alberta, Canada TOL 0W0
Dear Mr. Seebaluck:
This is in response to your request for information on the requirements applicable to nonspecification cylinders that are used as fire extinguishers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You described the aluminum cylinders as having volumetric capacities ranging from 70 cubic inches [1.15 L or 1,147.3 ml.] to 302 cubic inches [4.95 L], an operating pressure of 150 psi, and a minimum burst pressure of 900 psi. The cylinders will be imported into the United States from Canada.
Your nonspecification fire extinguishers must fully meet the limited quantity requirements contained in § 173.309(a) through (a)(3)(iv). Your cylinders appear to meet the internal volume limitation and the minimum burst pressure requirements prescribed in paragraph (a)(3)(i) and (ii). As stated in paragraph (a)(3)(iii), prior to initial shipment, each cylinder must be tested, without evidence of failure or damage, to at least three times its charged pressured at 21 C (70 'F). Each fire extinguisher must be marked with the test date and with the words "MEETS DOT REQUIREMENTS".
The extinguishing agent must meet the requirements in Special Provision 18 in § 172.102. Because the cylinders have capacities exceeding 900 ml (55 cubic inches), they may not contain any liquefied compressed gas. A cylinder charged with a non-liquefied gas, at a pressure of 300 psi or less at 21 C (70 'F), is not required to be fitted with a pressure relief device. See § 173.34(d)(2).
Shipments of the fire extinguishers must meet the shipping papers, packaging markings and, when offered for transportation by aircraft, the hazard warning labels requirements prescribed in Subparts C, D and E of Part 172, respectively. Shipments by air must also meet the per package
quantity limitations prescribed in the § 172.101 Hazardous Materials Table for the material and the general requirements in § 173.27. An electronic version of the HMR can be assessed through our internet web site at http://hazmat.dot.gov.
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.309
Regulation Sections
| Section | Subject |
|---|---|
| 173.309 | Fire extinguishers |