Interpretation Response #00-0291 ([Sakura Finetek U.S.A. Inc.] [Mr. Joseph Tan])

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

Interpretation Response Details

Response Publish Date: 01/10/2000

Company Name: Sakura Finetek U.S.A. Inc.

Individual Name: Mr. Joseph Tan

Location State: CA Country: US

View the Interpretation Document

Response text:

January 10, 2000

Mr. Joseph Tan                                                Ref. No. 00-0291
Warehouse Supervisor
Sakura Finetek U.S.A. Inc.
1750 W. 214 Street
Torrence, CA 90501

Dear Mr. Tan:

This is in response to your October 12, 2000 letter inquiring whether your company Is product, a refrigeration unit, identified as a Tissue-Tek Cryo 2000, would be considered a “Refrigerating machine, UN2857"  and, as such, not be subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

You state that the refrigeration unit consists of a cold chamber and a microtome, which provides the means for freezing and cutting tissues for pathological examination.  The machine contains 8-15 ounces of refrigerant R404A (pentaflouroethane and tetraflouroethane), is pressurized at 70­80 psi at 70 degrees Fahrenheit, and weighs 238 pounds.

Based on the information contained in your letter, it is our opinion that the Tissue-Tek Cryo 2000 would be considered a refrigerating machine.  Section 173.307(a)(4), as amended, provides that a refrigerating machine containing 25 pounds or less of a non-flammable, non-toxic, liquefied gas is not subject to the requirements of the HMR (Docket No. RSPA 99-6213 (HM-218), 65 FR 50450, August 18, 2000).

I hope this satisfies your request.  Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention.
Office of Hazardous Materials Standards

173.307

Regulation Sections