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Interpretation Response #09-0037 ([Thermo Fisher Scientific] [Mr. Gene Sanders])

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

Interpretation Response Details

Response Publish Date:

Company Name: Thermo Fisher Scientific

Individual Name: Mr. Gene Sanders

Location State: PA Country: US

View the Interpretation Document

Response text:

October 21, 2009





Mr. Gene Sanders, DGSA

Senior Dangerous Goods Transportation Specialist

Thermo Fisher Scientific, Customer Channel Group

2000 Park Lane

Pittsburg, Pennsylvania 15275

Ref. No. 09-0037

Dear Mr. Sanders:

This responds to your e-mail regarding the classification of hydrogen gas at low pressure under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the HMR apply to the transportation of a small quantity of hydrogen inside a glass tube or sphere if the hydrogen is shipped at a reduced pressure, rather than compressed.

According to the information provided with your email, the hydrogen gas is shipped within a glass tube with a total capacity of 1.7 ml. The gas is shipped at a pressure lower than atmospheric pressure (75 torr). In the event that the glass tube or sphere were to break, the amount of hydrogen released (0.17 ml) would be insufficient to ignite (i.e., in a 1-inch diameter tube or sphere, the concentration of the hydrogen would be below the 4% LEL).

It is the opinion of this office that when packaged as described in your e-mail, the hydrogen is not shipped in a quantity and form that poses an unreasonable risk to health and safety or property and, therefore, is not subject to regulation under the HMR.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

171.1, 172.101

Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions
172.101 Purpose and use of hazardous materials table