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