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Interpretation Response #17-0062

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

Interpretation Response Details

Response Publish Date: 02-08-2018
Company Name: Carbotainer SL    Individual Name: Antonio Ruiz
Location state: Z    Country: ES

View the Interpretation Document

Response text:

January 19, 2018

Antonio Ruiz
Carbotainer SL
Zaragoza 50003

Reference No. 17-0062

Dear Mr. Ruiz:

This letter is in response to your June 5, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to carbon fiber composite cylinders. You state that Carbotainer SL is a Spanish manufacturer of International Organization for Standardization (ISO) Standard 11119-2 carbon fiber composite cylinders with an aluminum liner and ask what steps (e.g., hazard communication and general requirements) are necessary to use these cylinders in the United States.

United Nations (UN) standard fibre-reinforced, composite gas cylinders with a load sharing metal liner must be designed and constructed in conformance with the applicable requirements prescribed in 49 CFR 178.70 and 178.71 for an ISO Standard 11119-2. Cylinders that fully conform to ISO Standard 11119-2 may be transported to, from, or within the United States and require a U.S. Department of Transportation competent authority approval (CA) per 49 CFR 178.69 and 178.70.

Manufacturers must mark these cylinders in conformance with 49 CFR 178.71(q), (r), and (s) to certify they are an authorized UN standard packaging. This includes a "USA" marking indicating the United States as a country of approval in conformance with 49 CFR 178.69 and 178.70. Once these requirements are met, the cylinders may be refilled in conformance with 49 CFR 173.301, 173.301b, and 173.304b; and must be periodically retested in conformance with 49 CFR 180.207.

Aluminum and steel liners allow for different materials to be transported. Certain materials, such as those with N86 in Column (7) of the Hazardous Materials Table in 49 CFR 172.101, forbid the use of aluminum alloy UN pressure receptacles.

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

178.70, 178.71, 178.69, 178.71(q), (r), 173.301, 173.301b, 173.304b, 180.207, 172.101

Regulation Sections

Section Subject
§ 172.101 Purpose and use of hazardous materials table