Interpretation Response #01-0025 ([Grayson Hill Farm] [Mr. Chris Schimp])

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

Interpretation Response Details

Response Publish Date: 06/26/2001

Company Name: Grayson Hill Farm

Individual Name: Mr. Chris Schimp

Location State: IL Country: US

View the Interpretation Document

Response text:

Jun 26, 2001

Mr. Chris Schimp                    Ref. No. 01-0025
Grayson Hill Farm
1705 Grayson Rd.
El Dorado, IL 62930

Dear Mr. Schimp:

This is in response to your letter and subsequent telephone conversations with a member of my staff asking whether you are required to apply for an exemption to transport methane gas as a Division 2.1 under the Hazardous Materials Regulations (HMR; 49 CFR' Parts 171-180). You state that a pressure vessel is filled with activated carbon which absorbs the methane. You also state that the activated carbon has been determined not to meet the definition for Division 4.2 and that the material will be described as Natural gas, compressed" UN1971.

Under the Hazardous Materials Regulations (HMR; Parts 100­185), an exemption is not required to transport methane gas containing activated carbon as a Division 2.1 hazardous material when prepared and packaged in conformance with the HMR. Section 173.22 states that it is the shipper's responsibility to properly classify a hazardous material. It is not the function of this Office to confirm findings. However, based on the information provided in your letter, it is the opinion of this Office that methane gas absorbed in activated carbon under pressure is appropriately described as Division 2.1.

A hazardous material described as "Natural gas, compressed," must be packaged in DOT specification cylinders in full conformance accordance with § 173.302. Cargo tank motor vehicles and other packagings are not authorized except under the terms of an exemption. You may submit an application for an exemption in accordance with the procedures prescribed in § 107.105.

I hope this information is helpful. Please contact us if you need further assistance.

Sincerely,

Hattie L. Mitchell, Chief
  Regulatory Review and Reinvention

  Office of Hazardous Materials Standards

173.22

Regulation Sections