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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 #15-0032 ([Air Liquide (USA) LLC] [Mr. Jerry Freeman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Liquide (USA) LLC

Individual Name: Mr. Jerry Freeman

Location State: TX Country: US

View the Interpretation Document

Response text:

July 28, 2015

Mr. Jerry Freeman
Director, Transportation Compliance
Air Liquide (USA) LLC
2700 Post Oak Blvd., Suite 325
Houston, TX  77056

Reference No. 15-0032

Dear Mr. Freeman:

This is in response to your February 9, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling requirements.  You provide a scenario where multiple sizes of UN specification cylinders containing a non-flammable gas UN1956.  You note the UN pressure vessels meet all specification requirements found in § 178.71 and are marked and labeled in accordance with Compressed Gas Association (CGA) C-7, Appendix A.  You further note that each cylinder will be packaged in a strong outer package in accordance with § 173.301b(c)(2)(vi).  Each cylinder will be placed inside an inner packaging and multiple cylinders, in these inner packagings, will be placed inside of a strong outer package.  You state the outer completed package will be properly marked and labeled, but ask if the inner packaging described in your request must be marked and labeled in accordance with subparts D and E of part 172.

The answer to your question is no.  In the situation you describe the cylinder itself is the package and would require appropriate marks and labels.  The definition of “overpack” from § 171.8 means “an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages.”  In the scenario you have provided marks and labels would only need to be carried over to the outermost overpack.     

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


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
173.301b(c)(2)(vi), 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.301b Additional general requirements for shipment of UN pressure receptacles