Interpretation Response #02-0096 ([Boeing Satellite Systems, Inc.] [Richard L. Walters])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Boeing Satellite Systems, Inc.
Individual Name: Richard L. Walters
Location State: CA Country: US
View the Interpretation Document
Response text:
Jul 11, 2002
Mr. Richard L. Walters Reference No. 02-0096
BSS Packaging Engineer
Boeing Satellite Systems, Inc.
P.O. Box 92919
Los Angeles, CA 90009-2919
Dear Mr. Walters:
This responds to your March 19, 2002 letter requesting clarification on the proper classification for pre-charged heat pipes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if your pre-charged heat pipes containing up to 260 grams of anhydrous ammonia when built without a reservoir and up to 400 grains of anhydrous ammonia with a reservoir may be shipped as Refrigerating Machines, 2.2, UN 2857, and, therefore, not subject to the HMR.
Under § 173.22, it is the shipper’s responsibility to properly class and prepare a hazardous material for shipment. This Office does not perform that function. However, based on the information provided in your letter, it is the opinion of this Office that your pre-charged pipes do not meet the criteria of §§ 173.306(e) or 173.307(a)(4) for Refrigerating Machines, 2.2, LTN2857 as listed in the §172.101 Hazardous Materials Table (HMT). As specified in §173.307(a)(4), “Refrigerating Machines, UN 2857” may contain non-flammable, non-toxic, liquefied gas or ammonia solution (UN 2672). Anhydrous ammonia (UN 1005) does not qualify under the § 173.307(a)(4) exception for refrigerating machines because it is a toxic gas. In addition, anhydrous ammonia is required to be shipped in authorized cylinders. Your pre-charged heat pipes are not authorized packagings under the HMR, and, may only be shipped under the terms of an exemption. Please refer to Part 107, Subpart B, § 107.105 for procedures for applying for an exemption.
As listed in the HMT, anhydrous ammonia is classed as a Division 2.2 material for domestic shipment and a Division 2.3 material, with a subsidiary Class 8 hazard for international shipment. In addition, ammonia solutions, depending on density and concentration, are classed as a Division 2.2 material for domestic shipment and a Division 2.3 material for international shipment, or a Class 8 material. For materials that are poisonous by inhalation, the entry "Poison-Inhalation Hazard" or "Toxic-Inhalation Hazard" and the words "Zone A", "Zone B", "Zone C", or "Zone D" for gases or "Zone A" or "Zone 13" for liquids, as appropriate, must be entered on the shipping papers. In addition, the words “Inhalation Hazard” must be marked on the packages.
I hope this answers your inquiry.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Standards
107.14(b)