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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 #07-0067 ([Alcoa KAMA] [Mr. Chris Meeks])

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

Interpretation Response Details

Response Publish Date:

Company Name: Alcoa KAMA

Individual Name: Mr. Chris Meeks

Location State: IL Country: US

View the Interpretation Document

Response text:

Jun 28, 2007


Mr. Chris Meeks                 Reference No. 07-0067
Alcoa KAMA
1050 Sycamore Rd.
Manteno, II 60950

Dear Mr. Meeks:

This is in response to your March 23, 2007 letter concerning limited quantity shipments of compressed gases under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request verification of your understanding of the exceptions provided for limited quantities of compressed gas when transported by highway.

In your letter, you state that § 173.306 provides labeling and packaging exceptions for compressed gases only when offered as a limited quantity not exceeding a gross weight of 30 kg (66 pounds). In your letter, you also state a 55-gallon steel drum (1A2) used as an outer packaging to contain aerosols and having a gross weight over 30 kg (66 pounds) may be offered and transported by highway, provided all applicable labeling and packaging requirements are maintained. You ask whether your interpretations are correct.

The answer is yes. When transported by highway, § 173.306 excepts limited quantities of certain compressed gases from: (1) labeling (except when intended for further transportation by air); and (2) specification packaging requirements when packaged in accordance with paragraphs (a)(1) through (a)(4) of § 173.306, unless required as a condition of the exception. Each package may not exceed 30 kg (66 pounds) gross weight. In addition, these shipments are not subject to: subpart F (Placarding) of part 172; part 174, except § 174.24; and part 177, except § 177.817.

In addition, a 55-gallon steel drum used as an outer packaging to contain aerosols and having a gross weight over 30 kg (66 pounds) may be offered and transported by highway. However, because the gross weight exceeds 30 kg (66 pounds), the limited quantity exceptions of § 173.306 would not apply, and all other applicable requirements in the HMR must be met, including labeling, placarding, and marking.

I hope this information is helpful.



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


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases