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Interpretation Response #08-0093 ([Woodard & Curran] [Ms. Kelly V. Camp])

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

Interpretation Response Details

Response Publish Date:

Company Name: Woodard & Curran

Individual Name: Ms. Kelly V. Camp

Location State: RI Country: US

View the Interpretation Document

Response text:

May 13, 2008

Ms. Kelly V. Camp CHMM

Senior Project Manger

Suite 100

95 Cedar Street

Providence, RI 02903

Ref. No.: 08-0093

Dear Ms. Camp:

This is in response to your March 25, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding a water pump system tank containing limited quantities of compressed gases. Your questions are paraphrased and answered below.

Q1: Section 173.306(g) specifies that "shipments are not subject to subpart F of this subchapter." Is the "subpart F" that is specified in this provision, Subpart F of Part 172?

A1. Yes. Also we will correct this oversight in a future rulemaking.

Q2: Section 173.306 is titled as "Limited Quantities of Compressed Gases." Is a water pump system tank that meets the packaging provisions in § 173.306(g) required to comply with all of the applicable limited quantity provisions such as § 172.203(b), which requires the addition of text to specify the described material as a limited quantity on the shipping paper, and § 172.315, which allows the use of the identification number instead of the proper shipping name to be marked on the packaging?

A2. Yes.

Q3. If a water pump system tank transported in accordance with § 173.306(g) has a special permit that allows for certain exceptions (e.g., a 24-inch diameter limit is expanded to a 26-inch diameter limit), do the rest of provisions such as the placarding exceptions still apply despite not being mentioned in the special permit?

A3. Yes. Unless the exception is specifically forbidden from use in the special permit, the exception would still be applicable.

Q4: Would the water pump system tank specified in Q3 be subject to both the applicable special permit provisions (e.g., §§ 172.203(a) and 172.301(c)) and the limited quantity

provisions (e.g., §§ 172.203(b) and 172.315(b))?

A4: Yes.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.203 173.306(g)

Regulation Sections

Section Subject
172.203 Additional description requirements
173.306 Limited quantities of compressed gases