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Interpretation Response #18-0031

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

Interpretation Response Details

Response Publish Date: 08-03-2018
Company Name: The Chemours Company    Individual Name: Mr. Randolph Martin
Location state: DE    Country: US

View the Interpretation Document

Request text:

August 3, 2018

Mr. Randolph Martin
Sr. Consultant, Hazardous Materials Distribution
The Chemours Company
1007 Market Street, Rm 3088
Wilmington, DE  19899

Reference No. 18-0031

Dear Mr. Martin:

This letter is in response to your February 27, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the definition of a Division 2.2 non-flammable, non-toxic gas.  You provide a scenario in which a gas exerts a gauge pressure of less than 200 kPa but is completely liquid at -50 °C, has a critical temperature of 138 °C, and exerts a gauge pressure of 163.3 kPa.  Specifically, you ask whether the gas as described meets the definition of a Division 2.2 gas under the HMR.

The answer is yes.  As prescribed in § 173.115(b), for the purposes of the HMR, a non flammable, nonpoisonous compressed gas (Division 2.2) means any material (or mixture) which—(1) Exerts in the packaging a gauge pressure of 200 kPa (29.0 psig/43.8 psia) or greater at 20 °C (68 °F), is a liquefied gas or is a cryogenic liquid, and (2) Does not meet the definition of Division 2.1 or 2.3.  Thus, regardless of pressure, a liquefied gas that complies with
§ 173.115(b)(2) meets the definition of a Division 2.2 non-flammable, non-toxic gas.

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

173.115(b), 173.115(b)(2)

Regulation Sections

Section Subject
§ 173.115 Class 2, Divisions 2.1, 2.2, and 2.3-Definitions