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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 #12-0118 ([RemTec International] [Ms. Patricia Burns])

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

Interpretation Response Details

Response Publish Date:

Company Name: RemTec International

Individual Name: Ms. Patricia Burns

Location State: OH Country: US

View the Interpretation Document

Response text:

August 15, 2012


Ms. Patricia Burns
RemTec International
100 Haskins Road
Bowling Green, OH 43402

Ref. No.: 12-0118

Dear Ms. Burns:

This is in response to your letter requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of non-DOT specification cylinders filled with a compressed gas and transported in a port area.  Specifically you ask if you can receive bromotrifluoromethane in non-DOT specification cylinders and subsequently transport the cylinders and transfer the bromotrifluoromethane to a DOT specification cylinder prior to leaving the port area in accordance with the provisions of § 171.25(d).

The answer is no, § 171.25(d) does not apply to the activities you describe, as it only authorizes the transportation of non-DOT specification cylinders, not the discharge of their contents. Conversely, § 171.23(a)(3) applies to transportation of imported cylinders for discharge within a single port area. In accordance with § 171.23(a)(3), imported non-DOT specification cylinders may be transported within a single port area and discharged if: (1) the Associate Administrator grants an approval for this activity; (2) the cylinders are certified as conforming with the transportation regulations of another country; (3) they are transported within a closed freight container; (4) the importer certifies that they provide an equivalent level of safety as comparable DOT specification cylinders; and (5) the cylinders are not refilled for export except in compliance with § 171.23(a)(4).

An application for an approval should contain a description of what is requested, operational and quality controls, packaging authorizations, and any other documentation sufficient to support the application. You may review complete requirements regarding approvals in §§ 107.701-107.717.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

171.23(a)(4), 171.25

Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
171.25 Additional requirements for the use of the IMDG Code