Interpretation Response #24-0028
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: KMC Systems, Inc.
Individual Name: Kevin Bourbeau
Location State: NH Country: US
View the Interpretation Document
Response text:
September 3, 2024
Kevin Bourbeau
Staff Mechanical Engineer
KMC Systems, Inc.
220 Daniel Webster Highway
Merrimack, NH 03054
Reference No. 24-0028
Dear Mr. Bourbeau:
This letter is in response to your April 23, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting refrigerating machines by air. Specifically, you ask whether an instrument containing two separate (i.e., isolated) refrigerating machines each containing up to 100 grams of R-290—a flammable, non-toxic gas—qualifies for the exception for compressed gases in refrigerating machines provided in § 173.307(a)(4)(v).
The answer is yes. Refrigerating machines and components thereof, containing 100 g or less of a flammable, non-toxic liquefied gas, are not subject to the requirements of the HMR. It is the opinion of this Office that this exception continues to apply to separate—and isolated—refrigerating machines regardless of whether the refrigerating machines component parts make up a larger instrument or piece of equipment. The refrigerating machines may not utilize the same tubing, piping, or relevant components to function.
Please note, if being transported in accordance with ICAO TI, special provision A103 may apply.
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
173.307(a)(4)(v)
Regulation Sections
| Section | Subject |
|---|---|
| 173.307 | Exceptions for compressed gases |