Minnesota Department of Transportation — Hazardous Materials Safety Interpretation

Page 1S. Departme Transportatic 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration JUL 18 2006 Hazardous Materials Specialist Mr. Kevin Kampa Ref. No. 06-0140 Minnesota of Transportation Department Office of Freight and Commercial Vehicle Operations 3485 Hadley Ave. Oakdale, MN 55128 Dear Mr. Kampa: This responds to your letter dated June 9, 2006, regarding the correct proper shipping name for a hydraulically pressurized article that contains a non-flammable gas under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- name for such an article under identification number UN3164 Specifically, you ask whether the proper shipping hydraulic; or (3) Hydraulic. would be: (1) Articles, pressurized hydraulic; (2) Articles, The entry corresponding to the identification number "JN3164 in the § 172.101 Hazardous Materials Table (HMT) is non-flammable gas." "Articles, pressurized pneumatic or hydraulic containing One of the terms, pneumatic or the material to be described. hydraulic is intended to be selected, as appropriate, for multiple proper shipping names under one entry in the HMT is The intent of combining effectiveness. to keep the table as short as possible without impairing its 172.101 060140#

Page 2article in the scenario you describe would be "Articles, Therefore, the most appropriate proper shipping name for an pressurized hydraulic." I trust this satisfies your inquiry. Please contact us if we can. be of further assistance. Sincerely, Hotte z. Neithe ll Hattie L. Mitchell Chief, Office of Hazardous Materials Standards Regulatory Review and Reinvention#

Page 3MINNESOTA Minnesota Department of Transportation 3485 Hadley Ave N Office of Freight and Commercial Vehicle Operations Phone: 651/747-2228 Oakdale, MN 55128 Fax: 651/747-2207 June 9, 2006 Stevens $/72.101 Ed Mazzullo- Director of Hazardous Materials Standards US DOT-PHMSA DHM-10 roper Shipping Name 400 7* Street SW 16-0142 Washington, DC 20590 Dear Mr. Mazzullo: I am inquiring about the proper shipping name that should be used for shipping UN3164. The table lists the following: Articles, Pressured Pneumatic or Hydraulic (containing non-flammable gas). The question is, what is the proper shipping name when shipping the Hydraulic version of this product? It appears it could be one of the following: Articles, Pressured Hydraulic; or Articles, Hydraulic; or just simply Hydraulic This shipping description appears unique on the table because there is no separate entry for pneumatic or hydraulic like there is with other shipping names with "qualifiers." (for example; Environmentally hazardous substance liquid, nos or solid, nos, have their own separate entries). Your assistance would be greatly appreciated. Kevin Kampa-Hazardous. Materials Specialist, Mn/DOT - OFCVO#