Interpretation Response #13-0089 ([Plunkett Cooney] [Mr. Jerome A. Galante])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Plunkett Cooney
Individual Name: Mr. Jerome A. Galante
Location State: MI Country: US
View the Interpretation Document
Response text:
July 18, 2013
Mr. Jerome A. Galante
Plunkett Cooney
38505 Woodward Ave.
Suite 2000
Bloomfield Hills, MI 48304
Ref. No. 13-0089
Dear Mr. Galante:
This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to aerosols. In your letter, you state that one of your clients recently became aware that R-134a aerosol refrigerant recharge product was being shipped in Department of Transportation (DOT) Specification 2Q containers exceeding 180 psig at 130 ºF. You ask whether the pressure in a DOT Specification 2Q container may exceed 180 psig at 130 ºF.
The answer is no. The pressure in a DOT Specification 2Q container may not exceed 180 psig at 130 ºF. Exceptions to this requirement may be authorized under the terms and conditions prescribed in a DOT special permit. A container authorized under a special permit bears a “DOT-SPXXXXX” mark in lieu of a “DOT 2Q” mark. You may wish to inform your client that they may file a complaint with our enforcement office at the following link: http://www.phmsa.dot.gov/feedback/hazmat-complaints-violations .
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.301