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Interpretation Response #20-0016


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

Interpretation Response Details

Response Publish Date: 05-04-2020
Company Name: SDS Refrigerant Service    Individual Name: Brian Conners
Location state: PA    Country: US

View the Interpretation Document


Response text:

May 4, 2020

Brian Conners
EPA Certified Reclaimer
SDS Refrigerant Service
4301 N. Delaware Avenue
Philadelphia, PA 19137

Reference No. 20-0016

Dear Mr. Conners:

This letter is in response to your February 18, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities of compressed gases. In your letter, you describe a refrigerant gas industry practice where companies facilitate transportation of DOT 39 cylinders containing "UN1028, Dichlorodifluoromethane" (refrigerant gas R12) as limited quantities. You note, with regard to these cylinders, that they are transported for purposes of reclaiming any remaining R12 in the cylinder because the gas is no longer produced. Further, you describe the shipping practice by reclaimers which involves providing a prepaid packaging that displays a limited quantity mark. Finally, you state that the cylinders are shipped by ground transportation as limited quantity material provided each completed package is less than 66 pounds. Specifically, you ask whether the use of the limited quantity provisions provided in § 173.306 is permitted for transportation of a DOT 39 cylinder containing R12 having a fluid capacity of 480 ounces and weighing up to 66 pounds.

The answer is no. Although "UN1028, Dichlorodifluoromethane" is an eligible material for the exceptions provided in § 173.306 (Limited quantities for compressed gases), a non-refillable DOT 39 cylinder with a fluid capacity of 480 ounces is not an authorized packaging for the exceptions listed in § 173.306.

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

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

173.306


Regulation Sections

Section Subject
§ 173.306 Limited quantities of compressed gases