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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 #13-0089 ([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: .

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels