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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 #17-0009

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

Interpretation Response Details

Response Publish Date:

Company Name: Airborne Labs International, Inc.

Individual Name: Mr. Tony Amato

Location State: NJ Country: US

View the Interpretation Document

Response text:

Dear Mr. Amato:


This letter is in response to your January 30, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinders.  Specifically, you reference numerous requirements in Part 173 and ask whether a pressure relief device (PRD) is required when shipping “UN1080, Sulfur hexafluoride, 2.2” or “UN1013, Carbon dioxide, 2.2” in Department of Transportation (DOT) Specification 3E-1800 sample cylinders with volumes of 150cc, 300cc, and 500cc, respectively.  


When shipping Division 2.2 non-flammable gases such as “UN1080, Sulfur hexafluoride, 2.2” or “UN1013, Carbon dioxide, 2.2” in DOT-3E-1800 sample cylinders, a PRD is required in accordance with the general requirements for cylinders in § 173.301(f).  However, § 173.301(f)(7) provides an exception for smaller quantities of carbon dioxide shipped in DOT‑3E cylinders.  This paragraph excepts DOT-3E cylinders up to 12 inches in length containing less than 8 ounces (236.5 cc) of carbon dioxide from the PRD requirement. 


I hope this information is helpful.  Please contact us if we can be of further assistance.



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

Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels