Interpretation Response #15-0086 ([HMT Associates, L.L.C.] [Mr. Andy Altemos])
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: Mr. Andy Altemos
Location State: VA Country: US
View the Interpretation Document
Response text:
July 28, 2015
Mr. Andy Altemos
HMT Associates, L.L.C.
6416 Grovedale Dr.
Alexandria, VA 22310
Reference No. 15-0086
Dear Mr. Altemos:
This is in response to your March 31, 2015 e-mail request regarding requirements under the International Maritime Dangerous Goods (IMDG) Code applicable to transport requirements for transport units used to transport flammable liquids under temperature control solely for commercial reasons. Specifically, you ask if section 7.3.7.6.2 of the IMDG Code requires explosion proof electrical fittings both inside and outside of the cooled compartment in which flammable liquids are loaded, or only within the cooled compartment for transport units used to transport flammable liquids under temperature control solely for commercial reasons.
Explosion proof electrical fittings are only required within the cooled compartment for transport units used to transport flammable liquids under temperature control solely for commercial reasons. Section 7.3.7.6.1 of the IMDG Code sets the general requirements applicable to all flammable gasses or liquids with a flashpoint under 23°C c.c. that are packed or loaded in a refrigerated transport unit regardless of safety or commercial reasons. This section requires the cooling or heating equipment to be in compliance with section 7.3.7.3. Sections 7.3.7.3.2.3 and 7.3.7.3.2.5, for single and dual mechanical systems respectively, only require explosion proof electrical fittings to be used within the coolant compartment.
Section 7.3.7.6.2, which prescribes requirements for flammable liquids having a flashpoint less than 23°C c.c. and not requiring temperature control for safety reasons which are transported under temperature control conditions for commercial reasons, states that explosion proof fittings are required except when the substance is transported at a control temperature at least 10 °C below its flashpoint. It is the opinion of this office that the reference to “explosion proof electrical fittings” in section 7.3.7.6.2 refers to explosion proof fittings in compliance with the requirements of 7.3.7.3.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division