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Interpretation Response #12-0162 ([Kiddie Fenwal Inc.] [Mr. Gil Walton])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kiddie Fenwal Inc.

Individual Name: Mr. Gil Walton

Location State: MA Country: US

View the Interpretation Document

Response text:

August 22, 2012

Mr. Gil Walton
Sr. Trade Analyst
Kiddie Fenwal Inc.
400 Main Street
Ashland, MA   01721

Ref. No. 12-0162

Dear Mr. Walton:

This responds to your August 1, 2012 letter regarding determination of the proper shipping name for your product under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In your incoming letter, you describe a 4BW steel cylinder containing a mixture of Heptafluoropropane (95-98%) a fire extinguishing agent, and nitrogen (2-5%) an expellant. Specifically, you ask if the concentration of 95-98% Heptafluoropropane would be considered technically pure, and therefore, be classified under the proper shipping name, "Heptafluoropropane, UN 3296, 2.2", as listed in the Hazardous Materials Table (HMT) in 172.101.

Section 173.22 states that it is the shipper's responsibility to properly classify a hazardous material. This office does not perform that function.  However, upon review of the information you supplied, it is the opinion of this office, that the most appropriate proper shipping description for the fire extinguishing system you described is "Fire extinguishers containing compressed or liquefied gas, UN 1044, 2.2."

I hope this answers your inquiry.  If you need additional assistance, please contact this office at (202) 366-8553.

Sincerely,

Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility