# Ms. Kristen Taddonio — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 06-0097
- **title:** Ms. Kristen Taddonio — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2006-07-11
- **effective on:** Not available
- **summary:** 06-0097 concerning 173.220, 173.306.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0097.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0097.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0097
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060097.pdf
**body:**

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of Transportation
U.S. Department
400 Seventh Street, S.W.
Washington, D.C. 20590
Pipeline and
Hazardous Materials Safety
Administration
JUL 11 2006
2450 Virginia Avenue, N. W.
Ms. Kristen Taddonio
Ref. No.: 06-0097
Apartment E-111
Washington, D. C. 20037
Dear Ms. Taddronio:
requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as
This responds to your letter dated April 13, 2006, regarding clarification of the:
they apply to the shipment of an air conditioning system accumulator installed in a motor
vehicle. In a subsequent phone conversation with a member of my staff, you said the ai
conditioning system contained a refrigerant gas accumulator built into the mechanics of
an automobile. Your questions are paraphrased and answered as follows:
Q1. Under §173.306(f)(1), accumulators installed in motor vehicles and fabricated
with a burst pressure of not less than five (5) times their charged pressure at
70°F.., when shipped, are not subject to the HMR. What requirements apply to an
fabricated to withstand 4.5 times the charged pressure at 70ºF?
air conditioning system accumulator installed in a motor vehicle if it is only
Al. In accordance with §173.306(f)(5), accumulators not conforming to the provisions
in a motor vehicle and fabricated to withstand only 4.5 times the charges
of paragraphs (t)(1) through (f)(4) of this section, (e.g., an accumulator installer
pressure may be shipped only under the terms of an approval issued by the
Associate Administrator of the Office of Hazardous Materials Safety.
Section 173.220(e) of the HMR specifies that items of equipment containing a
hazardous material, such as a compressed gas accumulator, that is an integra
component of a motor vehicle and necessary for the operation of the vehicle and
securely installed in the motor vehicle, are not subject to the HMR. Based on the
information you provided, the air conditioning system containing a refrigerant gas
accumulator built into the mechanics of the motor vehicle is not subject to the
173.306 (E)(5)
173.220 (e)
060097

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How does one apply for an approval?
You may apply for an approval in accordance with the requirements specified in
§107.705.
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Chief, Standards Development
Office of Hazardous Materials Standards

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Engrum
5113.3064)(1)
2450 Virginia Avenue Northwest
Apartment E-111
$17y70(c)
Washington, D.C. 20037
April 13, 2006
86-0097
U.S. Department of Transportation
Office of Hazardous Materials Safety
Research and Special Programs Administratio
400 7th St., S.W.
Washington, DC 20590
To whom it may concern:
I am writing to request clarification regarding 49 CFR 173.306 (f) (1). This regulation
states that "Accumulators installed in motor vehicles... fabricated with a burst pressure of
not less than five times their charged pressure at 70 degrees F, when shipped, are not
subject to the requirements of this subchapter." My questions are as follows:
1.
What requirements apply to the air conditioning system's accumulator if it is only
How can one apply for an exemption or exception?
fabricated to withstand 4,5 times the charged pressure at 70 degrees?
Your timely response is appreciated.
Thank you,
Paste Tadderio
Kristen Taddonio
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