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Interpretation Response #98-0202

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 08-07-1998
Company Name: Southeastern Fumigants, Inc.    Individual Name: Mr. Larry W. Massey
Location state: GA    Country: US

View the Interpretation Document

Response text:

AUG 7, 1998


Mr. Larry W. Massey                            Ref. No. 98-0202
Southeastern Fumigants, Inc.
P.O. Box 548
Dawson, Georgia 31742

Dear Mr. Massey:

This is in response to your letter dated June 12, 1998 regarding whether a "tube" located near the bottom of a 4BA 240 cylinder used to withdraw the liquid material out would be considered an "eduction tube" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You asked for clarification of what is considered an "eduction tube" for cylinders containing organic phosphates mixed with compressed gases under the HMR.

A tube used to facilitate the withdrawal of liquid from the bottom of a cylinder, as described in your letter, is an eduction tube.  As you are aware, the requirements in § 173.334(c)  prohibit cylinders containing organic phosphates mixed with compressed gases from being equipped with eduction tubes during transportation. 

Procedures for requesting exemptions from HMR requirements are set forth in 49 CFR 107.109 and 107.117.

I hope this satisfies your request.



                                                                                            Edward T. Mazzullo
                                                                                            Director, Office of Hazardous
                                                                                               Materials Standards


Regulation Sections

Section Subject
§ 173.334 Organic phosphates mixed with compressed gas