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Interpretation Response #12-0086 ([Pelchem] [Mr. EG Valkenburgh])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pelchem

Individual Name: Mr. EG Valkenburgh

Country: ZA

View the Interpretation Document

Response text:

June 21, 2012


Mr. EG Valkenburgh
P.O. Box 582
Pretoria, South Africa 0001

Reference No.: 12-0086

Dear Mr. Valkenburgh:

This responds to your March 15, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to pressure relief devices for cylinders. Specifically, you ask if a pressure relief device is required on a pressure cylinder filled with Xenon Difluoride using the proper shipping name, "UN3085, Oxidizing Solid Corrosive, n.o.s.?"

The answer is no. The Hazardous Materials Table (HMT) in § 172.101 designates approved non-bulk packagings for "UN3085, Oxidizing Solid Corrosive, n.o.s.," in §§ 173.211, 173.212, and 173.213 depending on the packing group. These sections allow for the use of cylinders as an approved non-bulk packaging for "UN3085, Oxidizing Solid Corrosive, n.o.s." In addition, § 173.301(f)(1) states that "a cylinder filled with a gas and offered for transportation must be equipped with one or more pressure relief devices." Therefore, because your cylinder only contains a solid material, and is thus not a gas, it would not be required to have a pressure relief device.

I hope 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

172.101, 173.211, 173.212, 173.213 & 173.301(f)(1)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.211 Non-bulk packagings for solid hazardous materials in Packing Group I
173.212 Non-bulk packagings for solid hazardous materials in Packing Group II
173.213 Non-bulk packagings for solid hazardous materials in Packing Group III
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels