Interpretation Response #24-0057
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: FHP Manufacturing
Individual Name: Mr. Scott D. Langston
Location State: FL Country: US
View the Interpretation Document
Response text:
October 24, 2024
Mr. Scott D. Langston
General Manager
FHP Manufacturing
601 N.W. 65th Court
Fort Lauderdale, FL 33309
Reference No. 24-0057
Dear Mr. Langston:
This letter is in response to your June 10, 2024, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting refrigerating machines. Specifically, you ask whether an appliance containing two separate (i.e., isolated) refrigerant circuits, each containing up to 12 kg (25 pounds) or less of a flammable, non-toxic gas, qualifies for the exception for compressed gases in refrigerating machines provided in § 173.307(a)(4)(iii).
The answer is yes, provided the refrigerating machine is not transported by air. Refrigerating machines and components thereof, containing 12 kg (25 pounds) or less of a flammable, non-toxic gas, are not subject to the requirements of the HMR, unless transported by air. 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 isolated refrigerant circuits may not utilize the same tubing, piping, or relevant components to function.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.307(a)(4)(iii)
Regulation Sections
| Section | Subject |
|---|---|
| 173.307 | Exceptions for compressed gases |