Interpretation Response #23-0036
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: National Association of Fire Equipment Distributors
Individual Name: Mr. David A. Pelton
Location State: IL Country: US
View the Interpretation Document
Response text:
July 19, 2023
Mr. David A. Pelton
Vice President, Technical
National Association of Fire Equipment Distributors
55 E. Monroe Street
Suite 1440
Chicago, IL 60603
Reference No. 23-0036
Dear Mr. Pelton:
This letter is in response to your March 20, 2023, letter and subsequent conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to non-specification fire extinguishers.
We have paraphrased and answered your questions as follows:
Q1. You ask whether there is a limit on the quantity of non-specification fire extinguishers classed as "UN1044, Fire extinguishers containing compressed or liquefied gas, 2.2" that can be packaged within a combination outer packaging (i.e., a suitable enclosure).
A1. The answer is no, there is no limit on the number of non-specification non-manifolded fire extinguishers that can be packaged within a combination outer packaging—provided it is a suitable enclosure and in conformance with all of the provisions of § 173.309(c).
Q2. You ask whether the combination outer packaging for "UN1044, Fire extinguishers containing compressed or liquefied gas, 2.2" must be 6-sided.
A2. The answer is no. As specified in § 173.309(c)(5), each non-specification fire extinguisher must be packaged as an inner packaging within a combination outer packaging. Examples of acceptable outer packagings for non-specification fire extinguishers include large cartons, racks, cages, or other suitable enclosures.
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
173.309(c), 173.309(c)(5)
Regulation Sections
| Section | Subject |
|---|---|
| 173.309 | Fire extinguishers |