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Interpretation Response #15-0118 ([National Association of Fire Equipment Distributors] [Mr. Norbert Makowka])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Association of Fire Equipment Distributors

Individual Name: Mr. Norbert Makowka

Location State: IL Country: US

View the Interpretation Document

Response text:

January 06, 2016

Mr. Norbert W. Makowka
Vice-President Technical
National Association of Fire Equipment Distributors
180 North Wabash, Suite 401
Chicago, IL 60601

Reference No. 15-0118

Dear Mr. Makowka:

This is in response to your June 15, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of carbon dioxide fire extinguishers. Specifically, you ask if the extinguishers may be described as "UN 1044, Fire extinguishers containing compressed or liquefied gas, 2.2 (non-flammable gas)." If not, you ask what the correct identification number, proper shipping name, marking and labeling requirements are for these devices.

You state the fire extinguishers are:

  • Made of either steel or aluminum and meet the specification requirements for a Department of Transportation (DOT) Specification 3 series seamless cylinder;
  • Hand-held units with a 5, 10, 15, or 20 pound capacity, or are wheeled units with a 50 pound capacity;
  • Filled with 100 percent "UN 1013, Carbon dioxide, 2.2" to a 90 percent fill density;
  • Manufactured and tested in conformance with the following American National Standards Institute, Inc. (ANSI) /Underwriters Laboratories, Inc. (UL), –
    • "Standard for Carbon-Dioxide Fire Extinguishers," ANSI/UL 154, CAN/ULC-S503, 2005, Revised 2010;
    • "Binational Standard for Rating and Fire Testing of Fire Extinguishers," ANSI/UL 711 CAN/ULC-S508; and
  • Recognized in the National Fire Protection Association (NFPA) "NFPA 10 Standard for Portable Fire Extinguishers"

Under the HMR, a fire extinguisher must contain 30 percent or less carbon dioxide by volume (see § 173.309(a)). Based on the information you provided, the carbon dioxide in your fire extinguishers exceeds this limit by 70 percent. Therefore, your fire extinguishers must be described as "UN 1013, Carbon dioxide, 2.2," marked as prescribed in § 172.301, and labeled with the NON-FLAMMABLE GAS label prescribed in § 172.415.

I hope this satisfies your request.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.309(a), 172.301, 172.415

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings
172.415 NON-FLAMMABLE GAS label
173.309 Fire extinguishers