Interpretation Response #21-0068
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Kajuligan, Inc.
Individual Name: Cliff Croft
Location State: IL Country: US
View the Interpretation Document
Response text:
October 21, 2021
Mr. Cliff Croft
Kajuligan, Inc.
S881 Donny Hill Road
Elburn, IL 60119-9655
Reference No. 21-0068
Dear Mr. Croft:
This letter is in response to your June 29, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of breathing oxygen (Boost Oxygen® brand) canisters. Specifically, you ask whether Boost Oxygen® canisters—which contain greater than 95% oxygen—should be classified as "UN3156, Compressed gas, oxidizing, n.o.s. (oxygen), 2.2" or "UN1072, Oxygen, compressed, 2.2."
Under § 173.22, it is the shipper's responsibility to class and describe a hazardous material. This Office does not normally perform this function. The hazard class is determined based on the predominant chemical composition and hazard properties of the material as it is being offered for transportation.
However, it is the opinion of this Office that Boost Oxygen® is at least 96% molecular oxygen and should be described as accurately as possible by the proper shipping name. If this understanding is correct, under "UN3156," this material would be described as "Compressed gas, oxidizing, n.o.s. (oxygen), 2.2," while under "UN1072," this material would be described as "Oxygen, compressed, 2.2." The "UN3156" identification number allows for other oxidizers to be present, potentially with molecular oxygen being in the minority of the mixture.
At a minimum of 96% molecular oxygen content, oxygen is the dominant component of the material and, therefore, is best suited to be classed as "UN1072, Oxygen, compressed, 2.2."
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
173.22
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |