Interpretation Response #14-0004 ([HMT Associates, L.L.C.] [Ms. Patricia Quinn])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HMT Associates, L.L.C.
Individual Name: Ms. Patricia Quinn
Location State: VA Country: US
View the Interpretation Document
Response text:
March 19, 2014
Ms. Patricia Quinn
HMT Associates, L.L.C.
603 King Street, Suite 300
Alexandria, VA 22314-3105
Ref. No. 14-0004
Dear Ms. Quinn:
This is in response to your January 8, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the filling capacity of cylinders manufactured and used under DOT-SP 10788. This special permit authorizes a non-specification cylinder, conforming to a specification DOT 39 cylinder, except that the requirement of § 173.302a(a)(1) is waived. Specifically, you ask if a cylinder authorized under DOT SP-10788 is subject to § 173.302a(a)(3) which limits the capacity of a DOT 39 cylinder not to exceed 1.23 L (75 cubic inches) when filled with a Division 2.1 material. In your letter you note that paragraph 7 of the special permit states that the cylinder’s maximum water capacity may not exceed 10 pounds (277 cubic inches).
The answer is yes. Cylinders manufactured or used under DOT-SP 10788 are subject to the
1.23 L (75 cubic inches) limit prescribed in § 173.302a(a)(3) when filled with a Division 2.1 material. DOT-SP 10788 provides that cylinders authorized under this special permit must conform to the requirements of a specification DOT 39 cylinder except that the requirement of § 173.302a(a)(1) is waived. The maximum water capacity of 10 pounds (277 cubic inches) referenced in paragraph 7 of the special permit is a standard requirement for DOT 39 cylinders with a service pressure exceeding 500 p.s.i.g. and not unique to DOT-SP 10788.
I hope this information is helpful. If you have further questions, please contact this Office.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Office of Hazardous Materials Standards
173.302a