Guidanceguidance
00-0291
Sakura Finetek U.S.A. Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration JAN 10 2001 Mr. Joseph Tan Reference No. 00-0291 Warehouse Supervisor Sakura Finetek U.S.A. Inc. 1750 W. 214 Street Torrence, CA 90501 Dear Mr. Tan: This is in response to your October 12, 2000 letter inquiring whether your company's product, a refrigeration unit, identified as a Tissue-Tek Cryo 2000, would be considered a "Refrigerating machine, UN2857" and, as such, not be subject to the Hazardous Materials Regulations HMR; 49 CFR Parts 171-180). You state that the refrigeration unit consists of a cold chamber and a microtome, which provides the means for freezing and cutting tissues for pathological examination. The machine contains 8 - 15 ounces of refrigerant R404A (pentaflouroethane and tetraflouroethane), is pressurized at 70- 80 psi at 70 degrees Fahrenheit, and weighs 238 pounds. Based on the information contained in your letter, it is our opinion that the Tissue-Tek Cryo 2000 would be considered a refrigerating machine. Section 173.307(a)(4), as amended, provides that a refrigerating machine containing 25 pounds or less of a non-flammable, non-toxic, liquefied gas is not subject to the requirements of the HMR (Docket No. RSPA 99-6213 (HM-218), 65 FR 50450, August 18, 2000). I hope this satisfies your request. Please contact us if we can be of further assistance. Sincerely, Hothe 2. Mitchill Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 173,307 000291#
Page 2SAKUR Sctober 12, 2000 173. 306(e),173.22 Ctassification Mr. Edward Mazzullo Director-OHMS/DHM-10 Proper Shipping Name 400 7TH Street SW J.S. D.O.T./RESPA 00-02.91 Washington, D.C., 20590 Dear Sir: Sakura Finetek U.S.A. Inc, based in Torrance, California is in business dealing with the health industry. Our products are used in laboratories and hospitals. I would like to request your good office for an opinion degrees Fahrenheit. The refrigerant's Materials Safety Data Sheet from the manufacturer (DuPont) indicates the following information: D.O.T./IMO Proper Shipping Name: TETRAFLOUROETHANE) LIQUEFIED GAS, N.O.S. (PENTAFLOUROETHANE AND UN Number: Hazard Class: 2.2 D.O.T./IMO Label: 3163 NONFLAMMABLE GAS "refrigerating machines" with UN 2857 under the Hazardous Materials Regulations (HMR: 49 CFR Parts At present, we consider the said item (The Tissue-Tek Cryo 2000 Cryostat) under the description 171-180), specifically, under the provisions of §173.306(e). We also consider the said product as ar unrestricted item in accordance with the provisions of § 173.307 (a)(4). The instrument is well built and securely packaged for transportation so it is highly improbable for the refrigerant to leak or escape under normal conditions. The entire packaging measures 43" × 45" × 61". I have enclosed photographs and a Sincerely oseph Tar Warehouse Supervisor Sakura Finetek U.S.A. Inc. 1750 W. 214" Street Torrance, CA., 90501 cc:HK SAKURA FINETEK U.S.A., INC. • 1750 WEST 214™ STREET • TORRANCE, CALIFORNIA 90501 TEL: (310) 972-7800, FAx: (310) 972-7888#
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