Interpretation Response #00-0159 ([Compliance and Response Management] [Mr. Henry Renfrew])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 08/15/2000

Company Name: Compliance and Response Management

Individual Name: Mr. Henry Renfrew

Location State: CT Country: US

View the Interpretation Document

Response text:

August 15, 2000

Mr. Henry Renfrew                Ref, No.00-0159
Compliance and Response Management
25 Audette Drive
Wallingford, CT 06492

Dear Mr. Renfrew:

This is in response to your letter dated May 12, 2000, requesting assistance in selecting an appropriate proper shipping name and packaging requirements for a mixture of Liquefied Petroleum Gases (LPG), 80% Butane and 20% Isobutane (which are expelled from 2Q inner containers, 8 oz.-227 gm, and used for heat/flame in small portable cooking appliances), under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  The 2Q inner containers are packaged in an outer packaging containing approximately 12 cans.  Your questions are paraphrased and answered as follows:

Ql.       Are the following descriptions the preferred or appropriate proper shipping name(s) for LPG containing 80% Butane and 20% Isobutane: "Petroleum gases"; " Liquefied petroleum gas"; or "Liquefied petroleum gases"?

Al.        When a material is not specifically listed by name in the §172. 1 01 Hazardous Materials Table (§172.101 HMT), selection of a proper shipping name must be made from the general description entries corresponding to the specific hazard class, packing group, and subsidiary hazards of the material.  In accordance with the §172.101 HMT, the most appropriate proper shipping name(s) for the LPG blend would be: "Petroleum gases, liquefied" or "Liquefied petroleum gas" or " gases".  Proper shipping names may be used in either the singular or plural (see §172.101 (c)(1) and (1 2)).

Q2.      Can the "Aerosols" description in the §172.101 HMT be used for the LPG blend (expelled as a vapor from- the container) and shipped under the limited quantity exceptions in §173.306 (a)(3) when it originates and is distributed in the United States by highway?

A2.      No. The exception in §173.306(a)(3) is limited to aerosol containers not exceeding one liter capacity in which one or more gases are used to expel other material that is a liquid, paste or powder.  A liquefied compressed gas (e.g., LPG blend) packaged without a liquid, paste, or powder in the container, is not eligible for the exception, and may not be described under the "Aerosols" description when shipped solely in domestic transportation by highway or rail.

For aircraft and vessel shipments, except as provided for limited quantities of compressed gases in containers of not more than 4 fluid ounces capacity under §173.306(a)(1), aerosols must meet the definition for "Aerosol" in §171.8 (See §171.11 (d)(14) and 171.12(b)(17)).

Q3.    Are the packagings in §173.304 (d)(3)(ii) acceptable for the LPG blend (packaged in inner 2Q containers having less than a maximum capacity of 31.83 cubic inches and less film the maximum charging pressure of 45 p.s.i.g. at 70 degrees F. and 105 p.s.i.g. at 130 degrees F.)?

A3.    The containers in §173.304 (d)(3)(ii) are authorized for the LPG blend and may be used within the limits of quantity and pressures specified in the table shown in this paragraph.  Such containers must be equipped with safety relief devices which will prevent rupture of the containers and dangerous projection of the closing devices when the containers are exposed to the action of fire.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.22

Regulation Sections