Interpretation Response #24-0058
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Alloy Products Corp.
Individual Name: Mr. Raymond Woo
Location State: WI Country: US
View the Interpretation Document
Response text:
October 1, 2024
Mr. Raymond Woo
Director of Engineering
Alloy Products Corp.
1045 Perkins Ave
Waukesha, WI 53186
Reference No. 24-0058
Dear Mr. Woo:
This letter is in response to your June 25, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of DOT specification cylinders for "UN3394, Organometallic substance, liquid, pyrophoric, water-reactive, 4.2 (4.3), PG I." You ask whether a DOT specification cylinder—such as a 4B or 4BA cylinder—is authorized for the transportation of "UN3394, Organometallic substance, liquid, pyrophoric, water-reactive, 4.2 (4.3), PG I."
The answer is yes. The authorized packagings for "UN3394" in § 173.181(a) include specification cylinders made from steel or nickel, provided the minimum design pressure is 175 psig. Both 4B (specifications found in § 178.50) and 4BA (specifications found in § 178.51) cylinders are made of steel. Therefore, these cylinders are authorized packagings provided the minimum design pressure is at least 175 psig and the cylinders—if equipped with valves—are protected as required by § 173.181(a)(3).
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.181(a), 173.181(a)(3), 178.50, 178.51