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Interpretation Response #04-0203 ([Chemical Accident Reconstruction Services, Inc.] [Mr. Michael Fox])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chemical Accident Reconstruction Services, Inc.

Individual Name: Mr. Michael Fox

Location State: AZ Country: US

View the Interpretation Document

Response text:

Mar 18, 2005


Mr. Michael Fox                Reference No. 04-0203
Chemical Accident Reconstruction Services, Inc.
9121 E. Tanque Verde Road, # 105
Tucson, Arizona. 85749

Dear Mr. Fox:

This is in response to your letter and subsequent telephone conversation with a member of my staff and Mr. Staniszewski of our Office of Hazardous Materials Technology requesting clarification on the testing requirements of aerosol containers, DOT 2P or 2Q under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80). Specifically, you request clarification of the provisions in § 173.306(a)(3)(ii). We apologize for the delay in responding and any inconvenience it may have caused.

Section 173.306(a)(3)(ii) requires a metal aerosol container to be capable of withstanding without bursting a pressure of one-and-one-half times the equilibrium pressure of the content at 130° F. The HMR do not specify a method for demonstrating that the container is capable of withstanding the specified pressure. You may demonstrate that the container meets the standard by testing or design specifications.

I hope this information is helpful. Please contact us if we can be of further assistance.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases