Interpretation Response #99-0278 ([Condon & Forsyth, LLP] [Mr. David F. Rifkind])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Condon & Forsyth, LLP
Individual Name: Mr. David F. Rifkind
Location State: DC Country: US
View the Interpretation Document
Response text:
November 8, 1999
Mr. David F. Rifkind Ref. No: 99-0278
Condon & Forsyth, LLP
1016 Sixteenth Street, NW
Washington, DC 20036
Dear Mr. Rifkind:
This is in response to your letter of October 5, 1999, concerning whether the helium or nitrogen cryogenic refrigerant system in a Magnetic Resonance Imaging machine (MRI) is subject to the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). You state that MRI"s will be reinstalled from fixed locations for installation at a new site.
As provided by § 173.320 (b) (2), the HMR do not apply to cryogenic atmospheric gases and helium when used in operation of a process system, such as a refrigeration system. It is the opinion of this Office that the MRI"s described fall within this exception.
I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.320
Regulation Sections
| Section | Subject |
|---|---|
| 173.320 | Cryogenic liquids; exceptions |