Interpretation Response #01-0075 ([Norcold] [Ms. Carol Bonner])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Norcold
Individual Name: Ms. Carol Bonner
Location State: OR Country: US
View the Interpretation Document
Response text:
APR 27, 2001
Ms. Carol Bonner Ref. No. 01-0075
Norcold
1 Century Drive
Gettysburg, OR 45328
Dear Ms. Bonner:
This responds to your March 1, 2001 letter requesting clarification on the proper description of your
refrigeration cooling units under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether you have properly described the refrigeration cooling units and whether the exception under § 173 .3 07(a) ( 4)(ii) applies.
According to your letter and follow-up telephone conversations with Deborah Boothe of my staff, Norcold produces absorption refrigeration units for the recreational vehicle industry. Each of the
cooling units contain ammonia solution, with the largest unit containing 1,250 milliliters of solution. The gross weight of the largest unit is 67 pounds. The pressure in the cooling unit is between 350-400 psig. Hydrogen is used as a charging agent or dispersant gas to disperse the ammonia solution in the cooling unit. The residual hydrogen, which remains in the cooling unit with the ammonia solution after charging, only amounts to about 12 grams or less for the largest unit manufactured.
Based on the information provided, it is the opinion of this Office that the exception provided in § 173.307 (a)( 4 )(ii) applies to the refrigerating machines and its components .c cooling units) manufactured by your company. Therefore, the refrigerating machines and the components (cooling units) are not subject to the HMR .
I hope this answers your inquiry.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.307(a)(4)
Regulation Sections
| Section | Subject |
|---|---|
| 173.307 | Exceptions for compressed gases |