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Interpretation Response #06-0161 ([Nazdar Limited] [Ms. Linda M. Bartram])

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

Interpretation Response Details

Response Publish Date:

Company Name: Nazdar Limited

Individual Name: Ms. Linda M. Bartram

Country: US

View the Interpretation Document

Response text:

Aug 22, 2006

Ms. Linda M. Bartram                  Reference No. 06-0161

DGSA, Shipping Manager

Nazdar Limited

7 Barton Road

Heaton Mersey Industrial Estate

Stockport SK4 3EG, Cheshire, England

Dear Ms. Bartram:

This is in response to your letter requesting clarification of the requirements contained in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if 0.19 mm aerosol cans filled with 400 ml of flammable liquid and tested to a pressure of 107 psig at 131°F may be transported in the United States under § 173.306.

Section 173.306(a)(3)(ii) requires aerosols pressurized to more than 140 psig but not exceeding 160 psig at 130°F to be transported in a specification DOT 2P inner metal container. For pressures exceeding 160 psig at 130°F a specification DOT 2Q inner metal container must be used. Because you are pressurizing the container to 107 psig at 131°F you are not required to use a specification DOT 2P or 2Q inside packaging. Provided your container otherwise complies with the HMR, including the provisions in § 173.306, it may be used for domestic transportation of aerosols.

I hope this information is helpful. Please contact us if you require additional assistance.


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

178.33, 178.33a

Regulation Sections

Section Subject
178.33 Specification 2P; inner nonrefillable metal receptacles