Interpretation Response #11-0111 ([Marv Golden Pilot Supplies] [Mr. Richard Golden])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Marv Golden Pilot Supplies
Individual Name: Mr. Richard Golden
Location State: CA Country: US
View the Interpretation Document
Response text:
June 21, 2011
Mr. Richard Golden
Marv Golden Pilot Supplies
8690 Aero Drive, Suite 102
San Diego, CA 92123
Ref. No.: 11-0111
Dear Mr. Golden:
This responds to your May 9, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of life-saving appliances. In your letter, you state that your company would like to ship twenty pounds or less of "UN2990, Life-saving appliances, self inflating, 9" by ground transportation. You indicate that these materials do not contain any hazardous materials, other than the small carbon dioxide cylinders that are required as part of the life-saving appliance. You specifically ask whether your materials, as described above, are eligible to utilize the exception provided § 173.219(c)(5).
Section 173.219(c)(5) specifies that, for other than transportation by aircraft, life saving appliances containing no hazardous materials other than carbon dioxide cylinders with a capacity not exceeding 100 cm3 are not subject to the provisions of the HMR provided they are overpacked in rigid outer packagings with a maximum gross mass of 40 kg. Therefore, provided your shipment meets all the requirements in § 173.219(c)(5), it would be eligible to utilize this exception.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.219
Regulation Sections
| Section | Subject |
|---|---|
| 173.219 | Life-saving appliances |