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Interpretation Response #03-0133 ([Manager of Sales Administration Hardringe Inc.] [Ms. Andra Russell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Manager of Sales Administration Hardringe Inc.

Individual Name: Ms. Andra Russell

Location State: NY Country: US

View the Interpretation Document

Response text:

Aug 25, 2003


Ms. Andra Russell                Reference No. 03-0133
Manager of Sales Administration Hardringe Inc.
P.O. Box 1507
One Hardringe Drive Elmira, NY 14902-1507

Dear Ms. Russell:

This is in response to your May 19, 2003 letter concerning the transportation of ,accumulators by vessel. Specifically, you ask whether the International Maritime Dangerous Goods (IMDG) Code provides an exception similar to that which is found in 173.306(f) (1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Section 173.306(f,) (1) specifies that accumulators, which are install~d in motor vehicles, construction equipment, and assembled machinery and designed and fabricated with a burst pressure of not less than five times their charged pressure at 70• F, when shipped, are not subject to the HMR.

The IMDG Code does provide a similar exception for accumulators under Special Provision 283 in paragraph 3.3.1. Special Provision 283 specifies that articles, containing gas, intended to function as shock absorbers, including impact-¬energy-absorbing devices or pneumatic springs, are not subject to the provisions of the IMDG Code provided: each article has a gas space capacity not exceeding 1.6L and a charge pressure not exceeding 280 bar where the product of the capacity
(liters) and charge pressure (bar) does not exceed 80; each article has a minimum burst pressure of 4 times the charge pressure at 20•C for products not exceeding 0.5L gas space capacity and 5 times charge pressure for products greater than 0.5L gas space capacity; each article is made of material that will not fragment upon rupture; each article is manufactured in accordance with a quality-assurance standard acceptable to the competent authority; and the design type has been
subjected to a fire test demonstrating that pressure in the article is relieved by means of a fire-degradable seal or other pressure-relief device, such that the article will not fragment and that the article does not rocket.

I hope this satisfies your request.



John A. Gale

Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases