Interpretation Response #11-0210 ([Patterson Companies, Inc.] [Mr. Robb Boros])

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

Interpretation Response Details

Response Publish Date: 11/10/2011

Company Name: Patterson Companies, Inc.

Individual Name: Mr. Robb Boros

Location State: IA Country: US

View the Interpretation Document

Response text:

November 10, 2011

Mr. Robb Boros

Patterson Companies, Inc.

1905 Lakewood Drive

Boone, Iowa 50036

Reference No.: 11-0210

Dear Mr. Boros:

This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the capability requirements for aerosol containers specified throughout § 173.306. Specifically, you seek clarification of the following language referenced in § 173.306(a)(5)(ii) with concern to aerosol capability.

"All non-DOT specification and specification DOT 2S containers must be capable of withstanding, without bursting, a pressure of one and one-half times the equilibrium pressure of the contents at 130 oF."

You ask if the temperature reference in § 173.306(a)(5)(ii) is referring to the equilibrium pressure, or the capability requirement, itself.

The temperature reference in § 173.306(a)(5)(ii) is intended to refer to the equilibrium pressure of the contents. Therefore, as specified in § 173.306(a)(5)(ii), all non-DOT specification and specification DOT 2S containers must be capable of withstanding, without bursting, a pressure of one and one-half times the equilibrium pressure of the contents, whatever this may be. Section 178.33b-7 addresses performance of DOT 2S containers at high temperatures.

I hope this satisfies your inquiry.

Sincerely,

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

173.306(a)(5)(ii), 178.33b-7

Regulation Sections