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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 #11-0161 ([Young & Franklin Inc.] [Mr. Greg Michalowski])

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

Interpretation Response Details

Response Publish Date:

Company Name: Young & Franklin Inc.

Individual Name: Mr. Greg Michalowski

Location State: NY Country: US

View the Interpretation Document

Response text:

September 1, 2011




Mr. Greg Michalowski

Compliance Engineer

Young & Franklin Inc.

920 Old Liverpool Road

Liverpool, NY 13088

Ref. No. 11-0161

Dear Mr. Michalowski:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities of compressed gases. Specifically, you ask whether the accumulator pictured in your letter while installed in assembled machinery with 1500 psi of nitrogen would be excepted from regulation under § 173.306(f)(1).

As specified in § 173.32 of the HMR, it is the responsibility of the shipper for properly classing a hazardous material that is to be offered for transportation. However, based on the information you provided, it appears that your product meets the requirements in § 173.306(f)(1), provided the accumulator is installed in motor vehicles, construction equipment, and assembled machinery and designed and fabricated with a burst pressure of not less than five times their charged pressure at 70 °F. It should also be noted that accumulators intended to function as shock absorbers, struts, gas spring, pneumatic springs or other impact or energy-absorbing devices are not subject to the HMR provided they meet the criteria specified in § 173.306(f)(4)(i) through (iv).

I hope this information is helpful. Please contact this office should you have additional questions.



T. Glenn Foster

Chief, Regulatory Review and Reinvention

Standards and Rulemaking Division

173.32, 173.306

Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases
173.32 Requirements for the use of portable tanks