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Interpretation Response #09-0228 ([Trinity Manufacturing, Inc.] [Ms. Karen Messana])

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

Interpretation Response Details

Response Publish Date:

Company Name: Trinity Manufacturing, Inc.

Individual Name: Ms. Karen Messana

Location State: NC Country: US

View the Interpretation Document

Response text:

January 19, 2010




Ms. Karen Messana

EHS & Regulatory Compliance Manager

Trinity Manufacturing, Inc.

11 E.V. Hogan Drive

Hamlet, NC 28345

Ref. No. 09-0228

Dear Ms. Messana:

This responds to your letter regarding the use of requalified foreign cylinders for the packaging of toxic by inhalation liquids under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether cylinders manufactured in accordance with the European ADR standard are permitted without further approval to package a Division 6.1, Hazard Zone B liquid (Chloropicrin, UN1580) under §§ 173.40 and 173.227 of the HMR once they are requalified in the United States as specified in § 171.23. Once successfully retested and refilled, the cylinders would be exported to a destination outside the United States.

The answer to your question is no. The conditions for packaging materials toxic by inhalation under international standards are specified in § 171.23(b)(10) which requires such materials to be packaged in accordance with the HMR. Section 173.227(a) specifies that a Hazard Zone B toxic liquid must be packaged in a seamless or welded DOT specification cylinder or a seamless UN standard cylinder conforming to § 173.40. Section 173.40 prescribes the specific requirements for the packaging of toxic materials in cylinders.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

171.23, 173.40, 173.227

Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
173.227 Materials poisonous by inhalation, Division 6.1, Packing Group I, Hazard Zone B
173.40 General packaging requirements for toxic materials packaged in cylinders