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Interpretation Response #09-0010 ([Pentair Water Group, Inc.] [Mr. John F. Di Leo])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pentair Water Group, Inc.

Individual Name: Mr. John F. Di Leo

Location State: IL Country: US

View the Interpretation Document

Response text:

March 26, 2009

Mr. John F. Di Leo

Pentair Water Group, Inc.

Import/Export Compliance Manager

450 Remington Road

Schaumburg, IL 60173

Ref. No.: 09-0010

Dear Mr. Di Leo:

This responds to your letter dated December 29, 2008 regarding clarification of the provisions in § 173.306(g) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to water pump system tanks transported by highway and vessel.

According to your letter, Pentair Water Group, Inc., (Pentair) sells steel water pump system tanks that are hooked up to a water pump in a basement or near a well to provide proper water pressure for a home or other building. The tank accomplishes this by the use of a bladder that has been pressurized, either with nitrogen or air, compressed to a gauge pressure of about 38-40 psi. You state that these articles are tested and safe up to 300 psi " or seven times their working and shipping pressure, fall under the hazardous material definition for a non-flammable, compressed gas (40 psig + 1 bar = 54.7 psia) and use either Nitrogen, UN1066, or Air, compressed, UN1002. In domestic transportation, Pentair ships these tanks in accordance with the limited quantity provisions in § 173.306(g).

You ask for clarification of the term "single-trip shipment", as used in § 173.306(g). In addition, you ask if the exception in § 173.306(g) for the steel water pump system tanks applies to ocean shipments moving under the International Maritime Dangerous Goods (IMDG) Code.

The exceptions applicable to water pump system tanks in § 173.306(g) specify that the tanks must be offered for transportation for single-trip shipment to installation sites. In this context, "single-trip shipment" means the one-time movement of tanks from the facility from which they are purchased to the site where they will be installed (e.g., from manufacturer/distributor to the end-user). Such shipments are not subject to the placarding requirements in subpart F of Part 172, to part 174 or part 177, except for the shipping paper requirements in § 174.24 and § 177.817 for rail and highway, respectively.

The limited quantity exception in § 173.306(g) for steel water pump system tanks does not apply to vessel or ocean shipments under the IMDG Code. Vessel shipments must be approved in writing by the Associate Administrator for Hazardous Materials Safety. The person requesting approval must provide a detailed description of the activity for which the approval is requested, including a tentative shipping description and all relevant data concerning the physical state of the material, temperature or other controls, and test results. Alternatively, the person requesting the approval may provide a copy of an approval issued by the competent authority of a foreign government. The procedures for applying for an approval are specified in §§ 107.705 and 107.709.

I hope this information is helpful. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Division

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases