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Interpretation Response #13-0236 ([Komatsu America Corporation] [Ms. Roxanna Marchand])

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

Interpretation Response Details

Response Publish Date:

Company Name: Komatsu America Corporation

Individual Name: Ms. Roxanna Marchand

Location State: IL Country: US

View the Interpretation Document

Response text:

February 25, 2014

Ms. Roxanna Marchand
Manager, Orders & Distribution
Komatsu America Corporation
2300 N.E. Adams Street
P.O. Box 240
Peoria, IL 61650

Reference No.: 13-0236

Dear Ms. Marchand:

This is in response to your December 5, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to fire extinguishers.  Specifically you ask what the proper shipping name would be for a manifolded unit that contains an extinguishing agent and separate DOT cylinder (or cartridge) containing nitrogen or a similar compressed gas used to expel the extinguishing agent.

Based on the information you provided, the system would most appropriately be described as UN1044, Fire Extinguisher.  When the cylinder or cartridge containing a compressed gas is installed in the fire extinguisher the complete unit must be described as a fire extinguisher.  When the cylinder containing the compressed gas is transported separately, the cylinder must be described with the name of its compressed gas contents.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.101, 173.309

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.309 Fire extinguishers