Interpretation Response #02-0313 ([K. W. Ritchey])

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

Interpretation Response Details

Response Publish Date: 01/31/2003

Company Name:

Individual Name: K. W. Ritchey

Location State: MO Country: US

View the Interpretation Document

Response text:

Jan 31, 2003

Mr. K. W. Ritchey                 Reference No.: 02-0313
708 E-15th Street
Kearney, MO 64060

Dear Mr. Ritchey:

this is in reference to your recent letter regarding the filling of manifolded carbon dioxide (CO2) cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You inquired about the filling of a manifolded "three bottle system" that you state is "tied into a fill station on the side of the building." You inquired whether the high pressure CO2 cylinders must "be removed and returned to an appropriate "scale" and "filling station" for proper and safe filling?"

You describe a cylinder filling technique that is possibly used at a customer's site.  The configuration consists of three manifolded high pressure cylinders (two cylinders serve as liquid cylinders and one serves as a vapor cylinder) or any combination of a multiple of three cylinders.  The "liquid" cylinders are filled with liquefied C02 to 90-95%, with a special fill manifold blocking the flow Of C02 to the "vapor" cylinder.  As the C02 expands, it vents through the fill manifold into the "vapor" cylinder.

Cylinders that are used at a work site and not offered for transportation come under the jurisdiction of the Department of Labor's Occupational Safety and Health Administration (OSHA).  You should contact OSHA or your state agency for information concerning such cylinders.

With regard to transportation, a liquefied gas may not be offered for transportation unless packaged in a DOT authorized (DOT specification or exemption) cylinder and filled in accordance with the applicable requirements specified in the HMR.  As specified in § 173.304a(a)(2) Table, the maximum permitted filling density for a cylinder filled with C02 is 68%.  That is, each cylinder may be filled with liquid to no more than 68% of its water weight capacity at 60 degrees F. See Note 1 following the § 173.304a(a)(2) Table and § 173.301(a)(8) and (g)(1).

I hope this satisfies you inquiry.  Should you have any further questions, please contact this office.

Sincerely,

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

173.304a

Regulation Sections