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Interpretation Response #12-0126 ([Leland Limited, Inc.] [Ms. Dawn Rakita])

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

Interpretation Response Details

Response Publish Date:

Company Name: Leland Limited, Inc.

Individual Name: Ms. Dawn Rakita

Location State: NJ Country: US

View the Interpretation Document

Response text:

July 24, 2012



Ms. Dawn Rakita
Assistant Vice President
Leland Limited, Inc.
PO Box 466
South Plainfield, NJ 07080

Reference No.: 12-0126

Dear Ms. Rakita:

This is in response to your May 30, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to shipments of UN 1072 Oxygen, compressed. You state that you ship UN 1072 Oxygen, compressed in small non refillable cylinders that meet the criteria for reclassification as ORM-D and are authorized to be shipped as a limited quantity under § 173.306 when you offer the product for transportation by ground. You ask if similar relief is available for shipments made by air.

The answer to your question is no. Shipments of UN 1072 Oxygen, compressed may not take the limited quantity or consumer commodity exceptions provided in § 173.306 because special provision A14 specifically prohibits this material from being transported as a limited quantity or consumer commodity in accordance with § 173.306 when transported aboard an aircraft.

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



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases