Interpretation Response #07-0143 ([PerkinElmer Optoelectronics] [Mr. David Harmon])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: PerkinElmer Optoelectronics
Individual Name: Mr. David Harmon
Location State: CA Country: US
View the Interpretation Document
Response text:
January 9, 2008
Mr. David Harmon
PerkinElmer Optoelectronics
44370 Christy Street
Fremont, CA 94538
Ref. No. 07-0143
Dear Mr. Harmon:
This responds to your email concerning the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to certain arc lamps containing small amounts of a Division 2.2 gas under pressure. Specifically, you ask if the lamps are subject to regulation under the HMR.
The lamps are manufactured by Cermax and PerkinElmer to a specification you provide and are offered for transportation in the packaging configurations described in your letter. We agree that Cermax and PerkinElmer brand lamps containing less than 30 mL of gas are transported in a quantity and form that will not pose an unreasonable risk to health, public safety or property during transportation. Therefore, it is our determination that they are not subject to regulation under the HMR.
However, the Cermax brand lamps containing between 68 mL and 270 mL of xenon and charged to a pressure between 275 psig and 500 psig are considered subject to the HMR due to the quantity of gas contained within them. These lamps must be described and transported in accordance with applicable HMR requirements. You may ship the lamps using the shipping description "UN 3363, Dangerous Goods in Apparatus, Class 9." You may also wish to consider using the limited quantity exceptions provided in § 173.306 for shipments of compressed gas. For international transportation, the lamps must be prepared for transportation in accordance with applicable international regulations.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Edward T. Mazzullo
Director
Office of Hazardous Materials Standards
173.306, 173.115, 173,22