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Interpretation Response #06-0284 ([Thompson Coburn LLP] [Mr. Anthony A. Anderson ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Thompson Coburn LLP

Individual Name: Mr. Anthony A. Anderson 

Location State: DC Country: US

View the Interpretation Document

Response text:

Mar 20, 2007


Mr. Anthony A. Anderson                 Reference No. 06-0284

Thompson Coburn LLP

Suite 600

1909 K Street, N.W.

Washington, D.C. 20006-1167

Dear Mr. Anderson:

This responds to your letter regarding the exceptions for limited quantities of compressed gases under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you represent a company who conducts chemical analyses on natural gas samples received from domestic and international sources in small single-use aluminum receptacles that have a volumetric capacity of less than 4 fluid ounces. The company is subject to substantial international shipping delays that occur because the receptacles are non-transparent. You ask whether a clear plastic pressurized receptacle of identical size and shape would be acceptable under the currently used description "Receptacles, small, containing gas (gas cartridges), 2.1, UN2 037."

The answer is yes. Under the HMR, containers having a volumetric capacity of 4 fluid ounces (7.22 cubic inches) or less are eligible for the limited quantity exceptions specified in § 173.306(a) (1). These exceptions include the allowance of non-specification pressure vessels (regardless of material of construction) and their outer packaging.

The packaging must meet the general requirements for packagings and packages specified in § 173.24. For international transportation by aircraft, similar provisions are contained in the International Civil Aviation Organization"s (ICAO"s) Technical Instructions for the Safe Transport of Dangerous Goods by Air.

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

173.24, 173.306 (a)(1)


Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
173.306 Limited quantities of compressed gases