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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 #11-0168 ([United Brands] [Mr. Jimmy Zahriya])

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

Interpretation Response Details

Response Publish Date:

Company Name: United Brands

Individual Name: Mr. Jimmy Zahriya

Location State: CA Country: US

View the Interpretation Document

Response text:

October 27, 2011




Mr. Jimmy Zahriya

United Brands

145 Bluxome Street

San Francisco, CA 94107

Ref. No. 11-0168

Dear Mr. Zahriya:

This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of compressed nitrous oxide and compressed carbon dioxide in non-specification cylinders. Specifically, you ask if aluminum chargers with a capacity of 10.2 mL that are filled with 8 mL or 8 gms of N2O and CO2 comply with § 173.306(a)(1) of the HMR.

The answer is yes. Under § 173.306(a)(1), a compressed gas placed in a non-specification container with a maximum capacity of four fluid ounces (7.22 cubic inches) or less may be described and transported as a limited quantity when it conforms to the provisions of this section. Note that the four fluid ounce (7.22 cubic inches) limit applies to the capacity of the container, not the volume of material contained in the container. This section excepts a limited quantity package from labeling, unless offered for transportation by air, and from the placarding and specification packaging requirements under the HMR. Additionally, the HMR permit the shipment of compressed nitrous oxide and compressed carbon dioxide by all modes of transportation.

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


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases