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Interpretation Response #99-0056 ([Radian International] [Mr. Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: Radian International

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

Apr 26, 1999

 

Mr. Andrew N. Romach                      Ref. No. 99-0056

Regulatory Compliance Manager

Radian International

Post Office Box 13000

Research Triangle Park, North Carolina 27709

Dear Mr. Romach:

This is in response to your letter of March 4, 1999, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the transportation of a Magnetic Resonance Imaging (MRI) Magnet machine by highway.  You state that the MRI machine contains helium, refrigerated liquid as a refrigerant to keep the system at a low temperature during transit.  Specifically, you ask whether the machine qualifies as a "process system"' under the provisions in 49 CFR § 173.320(b) (2) .

Based on the information you provided, the answer is yes.  The machine qualifies as a process system and, as provided by § 173.320(b)(2), is not subject to the requirements in 49 CFR Parts 171-180.

Sincerely,

 

Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.320

Regulation Sections