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Interpretation Response #98-0601 ([Safety & Compliance Associates, Inc.] [Mr. Mike Lopez])

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

Interpretation Response Details

Response Publish Date:

Company Name: Safety & Compliance Associates, Inc.

Individual Name: Mr. Mike Lopez

Location State: AL Country: US

View the Interpretation Document

Response text:

MAY 27, 1999


Mr. Mike Lopez
Safety & Compliance Associates, Inc.
P.O. Box 334
Trussville, AL 35173

Dear Mr. Lopez:

This is in response to your letter requesting clarification of certain requirements for cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answer~d as follows:

Q1. In § 173.302(e), what is meant by "representative of that day's compression"?

A1. As used in § 173.302(e) (1), "representative of ~hat day's compression" means that one cylinder taken from the population of cylinders filled each day must be checked for verification of container pressure.

Q2. May cylinders marked with a star be filled in a cluster, bank, group, rack or vehicle, provided such filling occurs within five years of the latest test date?

A2. No. Prior to refilling the cylinder, § 173.34 (e) (16) (i) requires that it must be removed from the cluster, bank, group, rack, or vehicle. The cylinder also must be removed in order to perform the hammer test that is prescribed in paragraph
(e) (16) (i) (C) .

Q3. Maya retest facility accept the cylinder owner's written or verbal assurance that provisions in § 173.34(e) (16) have been met?

A3. Yes, unless the retest facility has reason to believe non­compliance has occurred.

Q4. Maya cargo tank transporting "Oxygen, refrigerated liquid, Class 2.2, UN1073" display a UN number on the OXYGEN placard or must the IO number appear on a separate orange panel?

A4. Either may be used. Section 172.334(a) provides for the display of identification numbers on placards other than on a RADIOACTIVE, EXPLOSIVES 1.1, 1.2, 1.3, 1.4, 1.5 or 1.6, DANGEROUS, or subsidiary hazard placard. Section 172.519(b) (3) does not permit non-text placards, which display the symbol and class or division number only, for the OXYGEN placard. Therefore, either the identification number "1073" or the text "OXYGEN" must be displayed on the placard shown in § 172.520.

Q5. Maya non-bulk shipment of Class 2.1 or 2.2 material display ID numbers on placards?

A5. Yes, transport vehicles transporting non-bulk packages of Class 2.1 or 2.2 materials may display ID numbers on the FLAMMABLE GAS or NON-FLAMMABLE GAS placards in accordance with §§ 172.332 and 172.334.

Q6. A carrier has on the same vehicle a bulk package of "Carbon dioxide, refrigerated-liquid," UN2187 and non-bulk packages under 1,001 pounds aggregate"gross weight of "Carbon dioxide," UN1013. May a NON-FLAMMABLE GAS placard with the ID number UN2187 be used with a NON-FLAMMABLE GAS placard with no ID number, or must the orange panel with the ID number be used?

A6. Both placarding scenarios are acceptable. Placards and ID markings are required to be displayed for bulk packages as provided by § 172.514(a) (see §§ 172.302, 172.504) i however, they are not required for the non-bulk packages. For non-bulk packages, § 172.504(c) (1) provides a placarding exception for a transport vehicle carrying an aggregate gross weight of less than 454 kg (1,001 lbs.) of hazardous materials covered" by Table 2 of paragraph (e) of that section. The weight of the bulk package is excluded in determining the aggregate gross weight for this placarding exception.

I hope this information is helpful. If we can be of further assistance, please do not hesitate to contact this office.



Edward T.Mazzullo
Director, Office of Hazardous
Materials Standards


Regulation Sections

Section Subject
172.519 General specifications for placards