Interpretation Response #14-0209 ([BASF Corporation] [Mr. Gregory R. Knauf])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: BASF Corporation
Individual Name: Mr. Gregory R. Knauf
Location State: SC Country: US
View the Interpretation Document
Response text:
February 23, 2015
Mr. Gregory R. Knauf
Process/Project Engineer
BASF Corporation
1215 Greenville Highway
Central, SC 29630
Reference No. 14-0209
Dear Mr. Knauf:
This is in response to your recent e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the portable tank requirements for non-liquefied compressed gas. Specifically, you ask whether non-liquefied compressed gases such as "UN 1954, Compressed gas, flammable, n.o.s., 2.1 (flammable gas)" and "UN 1956, Compressed gas, n.o.s., 2.2 (non-flammable gas)" may be placed in portable tanks that are prescribed for liquefied compressed gas in § 173.315 and the "T" Code, T50, found in § 172.102.
The answer is yes. Non-liquefied compressed gases are typically transported under high pressure. To withstand this pressure, the HMR require the tanks that transport these materials to be designed and constructed as a United Nations (UN) T50 portable tank. These compressed gas in portable tanks requirements are located in § 173.315(a)(1) and (a)(2) of the HMR.
We appreciate your bringing to our attention that the title and language contained in § 173.315 may be confusing because they do not specifically mention that some of the requirements in this section also apply to non-liquefied compressed gas. We may consider clarifying this title and requirement in a future rulemaking.
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.315, 172.102, 173.315(a)(1) and (a)(2)