{"operation":"document","citation":"03-0133","title":"Manager of Sales Administration Hardringe Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-08-25","effective_on":null,"summary":"03-0133 response to Manager of Sales Administration Hardringe Inc. concerning 173.306.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0133.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0133.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0133","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030133.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nspecial Programs\nResearch and\nAdministration\nAUG 2 5 2003\nMs. Andra Russell\nManager of Sales Administration\nRef. No. 03-0133\nP.O. Box 1507\nHardringe Inc.\nOne\nHardringe\nDrive\nElmira,\nNY\n14902-1507\nDear Ms. Russell:\nThis is in response to your May 19, 2003 letter concerning the\nask whether the International Maritime Dangerous Goods (IMDG)\ntransportation of accumulators by\nvessel.\nSpecifically, you\n§ 173.306 (f) (1) of the\nCode provides an exception similar to that which is found in\n49 CFR Parts 171-180).\nHazardous Materials Regulations (HMR;\nSection 173.306 (f) (1) specifies that accumulators, which are\ninstalled in motor vehicles, construction equipment, and\npressure of not less than five times\nassembled machinery and designed and fabricated with a burst\n70° E, when shipped, are not subject to the HMR.\ntheir charged pressure at\nThe IMDG Code does provide a similar exception for\nSpecial Provision 283 specifies that articles, containing gas,\naccumulators under Special Provision 283 in paragraph 3.3.1.\nintended to function as shock absorbers, including impact-\nto the provisions of the IMDG Code provided: each article has\nenergy-absorbing devices or pneumatic springs, are not subject\nnot exceeding 280 bar where the product of the capacity\na gas space capacity not exceeding 1.6L and a charge pressure\n(liters)\nand charge pressure\narticle has a minimum burst pressure of 4 times the charge\n(bar) does not exceed 80; each\npressure at 20°C for products not exceeding 0.5L gas space\ncapacity and 5 times\n0.5L gas space capacity; each\nCharge pressure for products greater than\narticle is made of material that\nwill not fragment upon rupture; each article is manufactured\nin accordance with a quality-assurance standard acceptable to\nthe competent authority; and the design type has been\n173.306 (DU)\n030133\n\n<<<PAGE 2>>>\n\nsubjected to a fire test demonstrating that pressure in the\nother pressure-relief device,\narticle is relieved by means of\nsuch that the article will not\nfire-degradable seal or\nfragment and that the article does not rocket.\nI hope this satisfies your request.\nSincerely,\nOffice of Hazardous Materials Standards\nRegulations Specialist\n\n<<<PAGE 3>>>\n\n173.306 (f) (0\nOctober 23, 2002\nUS Department of Transportation\n03-0133\nTransportation Regulations Specialists\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nOffice of Hazardous Materials Standards\nWashington, D.C. 20590-0001\nSubject:\nIMDG Code Clarification Regarding Accumulators\nDear Sir/Madam:\nParham, Ref. No. 99-0318 (copy attached).\nIn researching past clarifications, a letter dated December 17, 1999 was written to Ms. Kathryn\nregarding accumulators. It was printed from the USDOT website in order to substantiate Hardinge's\nThe letter addresses the correct transportation method\nassembled machinery.\ninterpretation of the regulations regarding accumulators being transported, which are installed in\nassembled machinery and constructed with a burst pressure of at least five times their charged pressure\nAs provided by 49CFR 173.306(f)(1), accumulators which are installed in\nat 70° F are not subject to the HMR.\nis also clearly stated in the International Air Transportation Association (IATA) regulations, under Packing\nThe regulation pertaining to the transportation of accumulators installed in assembled machinery\nInstruction 208(a) for air transportation. However, a reference specifically pertaining to accumulators\n(IMDG) Code.\ninstalled in assembled machinery could not be found in the International Maritime Dangerous Goods\nlisted as a contact office of the designated competent authority in the IMDG Code, and, your letter to Ms.\nSince the US Department of Transportation, Research and Special Programs Administration is\nParham pertained specifically to accumulators installed in assembled machinery, would you please\naccumulators installed in assembled machinery?\nprovide\nclarification of the IMDG Code that specifically addresses the transportation, by ocean, of\nSincerely,\nManager of Sales Administration\nAndra Russell\nP.O. Box 1507\nHardinge Inc.\nElmira, NY 14902-1507\nOne Hardinge Drive\n607-378-4472 phone\n607-733-8182 fax","truncated":false,"body_characters":4243}