Ms. Kristen Taddonio — Hazardous Materials Safety Interpretation

Page 1of 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#

Page 2How 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#

Page 3Engrum 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#