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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0021 ([Airpack of Virginia, Inc.] [Mr. Hank Baird])

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

Interpretation Response Details

Response Publish Date:

Company Name: Airpack of Virginia, Inc.

Individual Name: Mr. Hank Baird

Location State: VA Country: US

View the Interpretation Document

Response text:

FEB 20, 2001

Mr. Hank Baird, Manager                      Ref. No. 01-0021
Airpack of Virginia, Inc.
Post Office Box 1098
Ashburn, VA 20146-1098

Dear Mr. Baird:

This is in response to your January 22, 2001 letter regarding the requirements for use of foreign made cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether the provisions of § 173.301(i)(1) stating that a charged cylinder manufactured outside the US may not be offered to, from or within the US unless it has been manufactured, inspected and tested in accordance with the applicable DOT specification as set forth in Part 178 applies to a foreign made cylinder of not more than 4 fluid ounce capacity shipped as a limited quantity under § 173.306(a)(1).

The answer is no. As provided by § 173.306(a)(1) a compressed gas may De offered in a non­specification container of not more than 4 fluid ounces capacity. The provisions of § 173.301 pertain only where a DOT specification cylinder is required.

I hope this information is helpful.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


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