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Interpretation Response #07-0119 ([Chain & Packaging 3M Materials Resource Division] [Mr. David D. Neitzel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chain & Packaging 3M Materials Resource Division

Individual Name: Mr. David D. Neitzel

Location State: MN Country: US

View the Interpretation Document

Response text:

Oct 19, 2007

Mr. David D. Neitzel                     Reference No. 07-0119

Specialist - MRD Supply

Chain & Packaging

3M Materials Resource Division

3M Center, Bldg. 223-6S-04

St. Paul, MN 55414-1000

Dear Mr. Neitzel:

This is in response to your request for a clarification of the requirements applicable to the stamping and approval of Multiple-element gas containers (MEGC) under § 178.74 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, your inquiry concerns allowable pressure receptacle specifications fitted within a MEGC framework manufactured in the United States after January 1, 2007.

In the scenario provided in your letter, you state that a MEGC has an attached data plate displaying both the United Nations (UN) stamp and the "USA" mark, and that the MEGC has been approved by an Independent Inspection Agency (IIA).

Your questions are paraphrased and addressed as follows:

Q1. Can the MEGC described above be fitted with dual stamped and approved DOT 3T/ISO 11120 pressure receptacles that are not additionally stamped with the "UN" and "USA" markings. Additionally, this arrangement has not been previously approved by the Associate Administrator as an "Alternative Arrangement."

Al. The answer is no. In accordance with § 178.71(o), the UN symbol and the mark of the country where the approval is granted must be marked on each UN pressure receptacle. A UN pressure receptacle manufactured within the United States, or transported to, from, or within the United States must be marked with "USA" as a country of approval in conformance with § 178.69 and 178.70. This requirement includes pressure receptacles fitted within a MEGC framework. In addition, the Alternative Arrangements provisions found under § 178.75 pertain to alternatives to design, construction, or testing of the MEGCs, and are not applicable to your scenario.

Q2. Does the definition of a multiple-element gas container specifically prohibit the use DOT specification cylinders or tubes within a MEGC.

A2. The definition of a "multiple-element gas container," in § 171.8, references "UN cylinders, tubes, or bundle of cylinders." DOT specification cylinders or tube are not included.

I hope this information is helpful.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

171.8, 178.71, 178.74

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
178.71 Specifications for UN pressure receptacles
178.74 Approval of MEGCs