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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.


Edward T. Mazzullo


Office of Hazardous Materials Standards

173.306, 173.115, 173,22

Regulation Sections

Section Subject
173.115 Class 2, Divisions 2.1, 2.2, and 2.3-Definitions
173.22 Shipper's responsibility
173.306 Limited quantities of compressed gases