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Interpretation Response #15-0223 ([Lloyd's Register EMEA] [Mr. Nigel Tijou])

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

Interpretation Response Details

Response Publish Date:

Company Name: Lloyd's Register EMEA

Individual Name: Mr. Nigel Tijou

Country: UK

View the Interpretation Document

Response text:

March 29, 2016

Mr. Nigel Tijou
Global Technical Manager – Containers
Technical and Quality Management
Inspection Services – Energy
Lloyd’s Register EMEA
1 Trinity Park, Bickenhill Lane
Birmingham B377ES   United Kingdom

Reference No.  15-0223

Dear Mr. Tijou:

This letter is in response to your November 13, 2015 email to Mr. Duane Cassidy, Chief, Pressure Vessels, Approvals and Permits Division, Pipeline and Hazardous Materials Safety Administration (PHMSA).  Your letter was forwarded to the Standards and Rulemaking Division for a response.  Specifically, you ask if a United Nations (UN) portable tank that transports “UN1689, Sodium cyanide, solid, 6.1, Packing Group (PG) I” is required to bear an American Society of Mechanical Engineers (ASME) Code stamp in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  

The HMR do not require UN1689 Sodium cyanide to be placed in an ASME Code-stamped UN standard portable tank.  As you noted in your original email, § 178.273(b)(6) requires UN portable tanks to be marked with an ASME Code only when they are intended for Division 6.1 liquids that meet inhalation toxicity for Hazard Zones A and B as defined in § 173.132, or materials that are designated as toxic (poisonous) by inhalation in the § 172.101 Table.

Under the HMR, UN1689 Sodium cyanide is a solid material, and this material is not designated as poisonous-by-inhalation in its entry on the § 172.101 Table, neither through use of a special provision entry nor through additional classification in §§ 173.211 or 173.242.    

I hope this information is helpful.  If you have any more questions, please do not hesitate to contact this Office.  


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

178.273(b)(6), 172.101, 173.211, 173.242

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.211 Non-bulk packagings for solid hazardous materials in Packing Group I
173.242 Bulk packagings for certain medium hazard liquids and solids, including solids with dual hazards
178.273 Approval of Specification UN portable tanks