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Interpretation Response #03-0203 ([Heritage Environmental Services, LLC-ETS] [Mr. David E. Blair])

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

Interpretation Response Details

Response Publish Date:

Company Name: Heritage Environmental Services, LLC-ETS

Individual Name: Mr. David E. Blair

Location State: WA Country: US

View the Interpretation Document

Response text:

Jan 19, 2005


Mr. David E. Blair                Reference No. 03-0203
Heritage Environmental Services, LLC-ETS
9730 Lathrop Industrial Drive
Suite El
Olympia, WA 98512

Dear Mr. Blair:

This responds to your letter regarding the classification and packaging requirements for compressed gas samples under the Hazardous Materials Regulations (HMR; 49 CER Parts 171-180).  Specifically, you request clarification of the shipping description and packaging requirements for cylinders containing unknown liquefied and compressed gas samples in DOT 3E cylinders. In addition, you ask if a previously issued letter from this Office on this subject, dated April 10, 1993, remains valid. We apologize for the delay in responding and any inconvenience it may have caused.

Our previously issued letter on this subject remains valid. Under § 172.101(c) (11), a sample of a material for which the hazard class is uncertain and must be determined by testing may be assigned a tentative proper shipping name, hazard class, identification number, and packing group, if applicable, based on the conditions specified in § 172.101(c) (11) (i) through (iv). A sample must be transported in the most appropriate packaging based on the tentative description assigned and the physical state of the material.

The general packaging requirements for compressed gases in cylinders are found in § 173.301. DOT 3E cylinders must be shipped in strong outer packagings, as required by
§ 173.301(a) (9). The packaging method described in your letter satisfies this requirement if a tentative non-toxic classification is assigned to the gas sample. However, a packaging containing a cylinder filled with a suspected toxic gas or mixture (see § 173.115(c) and 173.116) must conform to the additional requirements of § 173.40 and CGA Pamphlets S-1.1 and S-7.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



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


Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels