Interpretation Response #06-0142 ([Associated Spring Raymond] [Mr. Thomas J. Fischer])

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

Interpretation Response Details

Response Publish Date: 07/07/2006

Company Name: Associated Spring Raymond

Individual Name: Mr. Thomas J. Fischer

Location State: OH Country: US

View the Interpretation Document

Response text:

Jul 7, 2006

Mr. Thomas J. Fischer                 Reference No. 06-0142
Associated Spring Raymond
1705 Indian Wood Circle, Suite 210
Maumee, OH 43537

Dear Mr. Fischer:

This is in response to your letter requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to nitrogen-charged gas springs. You ask for confirmation of your understanding that the gas springs are not regulated under the HMR, although you state: “Shipping via air will still require proper coding (UN1066), labeling (non-flammable) and the proper hazardous paperwork to be compliant with IATA standards for air transportation.”

Accumulators intended to function as gas springs or other impact or energy-absorbing devices are not subject to the HMR provided they meet the criteria specified in
§ 173.306(f)(4). Such gas springs also are not subject to the International Civil Aviation’s (ICAO) Technical Instructions provided they meet the Technical Instruction’s criteria in Special Provision Al14. The HMR authorizes the use of the ICAO Technical Instructions with certain exceptions as an alternative to the HMR, but does not authorize the use of the IATA Dangerous Goods Regulations. For questions regarding the use of the IATA Dangerous Goods Regulations, we suggest you contact the organization at
514/390-6770.

I hope this information is helpful. Please contact this office should you have additional questions.

Sincerely,

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

173.306 (f)(4)

Regulation Sections