Interpretation Response #07-0067R ([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: 09/06/2007

Company Name: Alcoa KAMA

Individual Name: Mr. Chris Meeks

Location State: IL Country: US

View the Interpretation Document

Response text:

SEP 6, 2007

Mr. Chris Meeks                             Ref. No. 07-0067 R

Alcoa KAMA

1050 Sycamore Rd.

Manteno, Il 60950

Mr. Meeks:

This is in further response to our July 28, 2007 reply to your March 30, 2007 letter concerning limited quantity shipments of compressed gases transported by highway. A further review of this issue indicates a need to clarify our previous response.

Your letter stated that § 173.306 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) 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). Your letter also stated that 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 asked whether your interpretations were correct.

In our response, we indicated that 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.

It was not out intention to imply that a 55-gallon steel drum is an acceptable packaging for aerosols. The only packaging section for this material is § 173.306 as indicated under the "Exceptions" column of the HMT. The HMR does not authorize aerosols to be transported in a package with a gross weight that is greater then 30 kg (66 pounds).

I hope this information is helpful.

Sincerely,

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

173.306(a)

Regulation Sections