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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 #13-0053 ([OBO/CFSM/FAC/PS,] [Ms. Heidi I. Barranco-Fisher])

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

Interpretation Response Details

Response Publish Date:

Company Name: OBO/CFSM/FAC/PS,

Individual Name: Ms. Heidi I. Barranco-Fisher

Location State: VA Country: US

View the Interpretation Document

Response text:

May 6, 2013

 

Ms. Heidi I. Barranco-Fisher
OBO/CFSM/FAC/PS, Room 1202
1701 North Fort Myer Drive
Arlington, VA 22219

Reference No.: 13-0053

Dear Ms. Barranco-Fisher:

This is in response to your February 21, 2013 email to the Approvals and Permits Division of the Office of Hazardous Materials Safety requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of Trichlorofluoromethane (R-11 refrigerant).   

You present a scenario where the Environmental Security Protection System Team within the U.S. Department of State is transporting cylinders used for testing filtration systems installed in U.S. Department of State diplomatic buildings.  Each cylinder contains four (4) pounds of R-11 refrigerant.  The cylinders are packaged separately in aluminum carrying cases and transported by highway or carried aboard passenger aircraft as checked baggage.  You ask whether the transportation of the R-11 refrigerant is regulated or prohibited under the HMR or the International Civil Aviation Organization, Technical Instructions for the Safe Transportation of Dangerous Goods by Air (ICAO-TI).

Trichlorofluoromethane (R-11 refrigerant) in the quantity and package described is not regulated and not prohibited under the HMR or ICAO-TI for transportation by air or highway.

Trichlorofluoromethane (R-11refrigerant) is not regulated as a hazardous material under the HMR or the ICAO-TI for transportation by air or highway unless it meets one or more  of the following conditions:  It is listed in the HMR § 172.101 hazardous materials table, or Table 3-1 (Dangerous Goods List) of the ICAO-TI; it meets the HMR or ICAO-TI definition of one or more hazard classes (in this instance, a gas); or it meets the HMR definition of a hazardous substance.

(1) Neither trichlorofluoromethane or R-11 refrigerant is listed in the HMR § 172.101 hazardous materials table, or Table 3-1 (Dangerous Goods List) of the ICAO-TI.  

(2) The HMR § 171.8 definition of a hazardous substance, is a material that is listed in appendix A to HMR § 172.101 (the hazardous substances table) and is in a quantity in one package which equals or exceeds the reportable quantity (RQ).

Trichlorofluoromethane is listed in the hazardous substances table as
trichloromonofluoromethane with an RQ of 5,000 pounds.  The quantity of trichlorofluoromethane being transported in each package (4 pounds) is less than 5,000 pounds.  The material as packaged does not meet the HMR § 171.8 definition of a hazardous substance.   

(3) The HMR § 171.8 and ICAO-TI 2;2.1.1 definition of a gas is a material which has a vapor pressure greater than 300 kPa (43.5 psia) at 50 °C (122 °F) or is completely gaseous at 20 °C (68 °F) at a standard pressure of 101.3 kPa (14.7 psia).

The material safety data sheet for R-11 refrigerant provides a boiling point of   74.5 °F and a vapor pressure of 12.8 psia at 68 °F.  Additional information obtained from the supplier of the R-11 refrigerant provides a vapor pressure of 35.7 psia at 125 °F.  Since the boiling point of the R-11 refrigerant is 74.5 °F it would not be completely gaseous at 68 °F.  Further, the vapor pressure of the R-11 refrigerant is 35.7 psia at 125 °F which is less than 43.5 psia at 122 °F.  Therefore, R-11 refrigerant does not meet the HMR § 171.8 and ICAO-TI 2;2.1.1 definition of a gas.

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

Sincerely,

Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

172.101, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table