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Interpretation Response #13-0122R ([URS Corporation] [Mr. Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

AUG 12  2013

Mr. Andrew N. Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC   27560

Ref. No. 13-0122R

Dear Mr. Romach:

This responds to your June 6, 2013, letter requesting clarification on shipping shock absorbers, “Articles, pressurized, pneumatic UN3164” under   § 173.306(f) of the Hazardous Materials Regulations (HMR; Parts 171-180).  Specifically, you ask for confirmation that shock absorbers shipped under § 173.306(f)(2) and (f)(3) qualify for the limited quantity exception and are excepted from shipping paper and placarding requirements.

According to your letter, it is your understanding that shock absorbers may be shipped as limited quantity under § 173.306(f)(2) and (f)(3); and would be allowed to be packaged in a strong outer packaging with the limited quantity marking applied in accordance with
§ 172.315(a); and would be excepted from labeling, shipping papers, and placarding requirements.  

Limited quantity exceptions for Class 2 compressed gases are provided in § 173.306(a).  If the shock absorbers meet any of the exceptions provided for limited quantities in § 173.306(a), then they may be shipped as a limited quantity.  However, if the shock absorbers do not meet any of the limited quantity exceptions in § 173.306(a), then the exceptions in § 173.306(f) would apply.  Shock absorbers shipped under § 173.306(f)(2) are excepted from labeling, specification packaging, and placarding.  Shock absorbers shipped under § 173.306(f)(3) are excepted from labeling, specification packaging, but are not excepted from placarding requirements.  Therefore, as stated in interpretation letter Ref. No. 08-0270, shock absorbers conforming to the requirements in § 173.306(f)(3) are not excepted from placarding requirements.  

PHMSA acknowledges that the title of § 173.306, “Limited Quantities of Compressed Gases” may lead some to the conclusion that complying with subparagraphs of this section (e.g. § 173.306(f)) would indicate that the material can be considered a limited quantity. However, this is only the case if the subparagraph indicates an allowance for limited quantity.  PHMSA may consider clarifying the title of § 173.306 in a future rulemaking.

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



Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

173.306(f), 172.315




Regulation Sections

Section Subject
172.315 Limited quantities
173.306 Limited quantities of compressed gases