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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

Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels