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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #08-0270 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

November 7, 2008

Mr. Andrew Romach

Regulatory Compliance Manager

URS Corporation

1600 Perimeter Park Drive

Morrisville, NC 27560

Ref. No.: 08-0270

Dear Mr. Romach:

This is in response to your October 28, 2008 letter requesting clarification of the non-bulk shipping requirements for shock absorbers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if shock absorbers that are classed as "Articles, pressurized pneumatic, UN3164" may be shipped together in non-specification outside packaging (e.g., large fiberboard box or metal cage) and whether they are excepted from DOT hazard labeling and placarding requirements.

In accordance with § 173.306(f)(3), the shock absorbers are excepted from labeling (unless offered for transportation by aircraft) and specification packaging requirements. To take advantage of these exceptions, each shock absorber must be designed and fabricated with a burst pressure of not less than five times its charged pressure at 70°F when shipped. In addition, each shock absorber must be shipped as an inside packaging (outer packaging may consist of a large fiberboard box or metal cage that meets the general packaging requirements in Part 173), have a gas space under stored pressure of 2,500 cubic inches or less, and be tested before initial shipment and before each refilling and reshipment without evidence of failure or damage. Shock absorbers conforming to the requirements in § 173.306(f)(3) are not excepted from placarding requirements.

I hope this information is helpful. Please contact us if you require additional assistance.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases