Manager of Sales Administration Hardringe Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 special Programs Research and Administration AUG 2 5 2003 Ms. Andra Russell Manager of Sales Administration Ref. No. 03-0133 P.O. Box 1507 Hardringe Inc. One Hardringe Drive Elmira, NY 14902-1507 Dear Ms. Russell: This is in response to your May 19, 2003 letter concerning the ask whether the International Maritime Dangerous Goods (IMDG) transportation of accumulators by vessel. Specifically, you § 173.306 (f) (1) of the Code provides an exception similar to that which is found in 49 CFR Parts 171-180). Hazardous Materials Regulations (HMR; Section 173.306 (f) (1) specifies that accumulators, which are installed in motor vehicles, construction equipment, and pressure of not less than five times assembled machinery and designed and fabricated with a burst 70° E, when shipped, are not subject to the HMR. their charged pressure at The IMDG Code does provide a similar exception for Special Provision 283 specifies that articles, containing gas, accumulators under Special Provision 283 in paragraph 3.3.1. intended to function as shock absorbers, including impact- to the provisions of the IMDG Code provided: each article has energy-absorbing devices or pneumatic springs, are not subject not exceeding 280 bar where the product of the capacity a gas space capacity not exceeding 1.6L and a charge pressure (liters) and charge pressure article has a minimum burst pressure of 4 times the charge (bar) does not exceed 80; each pressure at 20°C for products not exceeding 0.5L gas space capacity and 5 times 0.5L gas space capacity; each Charge pressure for products greater than article is made of material that will not fragment upon rupture; each article is manufactured in accordance with a quality-assurance standard acceptable to the competent authority; and the design type has been 173.306 (DU) 030133#

Page 2subjected to a fire test demonstrating that pressure in the other pressure-relief device, article is relieved by means of such that the article will not fire-degradable seal or fragment and that the article does not rocket. I hope this satisfies your request. Sincerely, Office of Hazardous Materials Standards Regulations Specialist#

Page 3173.306 (f) (0 October 23, 2002 US Department of Transportation 03-0133 Transportation Regulations Specialists Research and Special Programs Administration 400 Seventh Street, S.W. Office of Hazardous Materials Standards Washington, D.C. 20590-0001 Subject: IMDG Code Clarification Regarding Accumulators Dear Sir/Madam: Parham, Ref. No. 99-0318 (copy attached). In researching past clarifications, a letter dated December 17, 1999 was written to Ms. Kathryn regarding accumulators. It was printed from the USDOT website in order to substantiate Hardinge's The letter addresses the correct transportation method assembled machinery. interpretation of the regulations regarding accumulators being transported, which are installed in assembled machinery and constructed with a burst pressure of at least five times their charged pressure As provided by 49CFR 173.306(f)(1), accumulators which are installed in at 70° F are not subject to the HMR. is also clearly stated in the International Air Transportation Association (IATA) regulations, under Packing The regulation pertaining to the transportation of accumulators installed in assembled machinery Instruction 208(a) for air transportation. However, a reference specifically pertaining to accumulators (IMDG) Code. installed in assembled machinery could not be found in the International Maritime Dangerous Goods listed as a contact office of the designated competent authority in the IMDG Code, and, your letter to Ms. Since the US Department of Transportation, Research and Special Programs Administration is Parham pertained specifically to accumulators installed in assembled machinery, would you please accumulators installed in assembled machinery? provide clarification of the IMDG Code that specifically addresses the transportation, by ocean, of Sincerely, Manager of Sales Administration Andra Russell P.O. Box 1507 Hardinge Inc. Elmira, NY 14902-1507 One Hardinge Drive 607-378-4472 phone 607-733-8182 fax#