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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #03-0323 ([Air Liquide America L.P.] [Mr. Ralph Diaz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Liquide America L.P.

Individual Name: Mr. Ralph Diaz

Location State: TX Country: US

View the Interpretation Document

Response text:

May 11, 2004


Mr. Ralph Diaz                 Reference No. 03-0323
Air Liquide America L.P.
2700 Post Oak Blvd.
Houston, Texas 77056

Dear Mr. Diaz:

This is in response to your letter requesting clarification of the cylinder valve protection requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether the provisions in § 173.301 (h) (2) (iv) would allow cylinders to be unloaded by the consignor instead of the consignee, as required by that section.

The answer is yes.  Section 173.301(h) (2) describes the conditions under which cylinders manufactured before October 1, 2007 must have their valves protected during transportation.  Specifically, § 173.301 (h)(2)(iv) requires that a cylinder valve to be protected by loading the cylinder in an upright position and securely bracing it in a rail car or motor vehicle, provided that the cylinders are loaded by the consignor and unloaded by the consignee.  It is the intent of this provision to limit the handling of the cylinders to the consignor and consignee, only.  Therefore it would be acceptable for the consignor to unload the cylinders at the consignee’s site.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.



John A. Gale
Chief, Standards Development
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