{"operation":"document","citation":"06-0142","title":"Associated Spring Raymond — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-07-07","effective_on":null,"summary":"06-0142 response to Associated Spring Raymond concerning 173.306.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0142.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0142.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0142","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060142.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nAdministration\nHazardous Materials Safety\nJUL 7 2006\nMr. Thomas J. Fischer\nAssociated Spring Raymond\nRef. No. 06-0142\n1705 Indian Wood Circle, Suite 210\nMaumee, OH 43537\nDear Mr. Fischer:\nThis is in response to your letter requesting clarification of the applicability of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to nitrogen-charged gas\nregulated under the HMR, although you state: \"Shipping via air will still require proper\nsprings. You ask for confirmation of your understanding that the gas springs are not\ncompliant with IATA standards for air transportation.\"\ncoding (UN1066), labeling (non-flammable) and the proper hazardous paperwork to be\ndevices are not subject to the HMR provided they meet the criteria specified in\nAccumulators intended to function as gas springs or other impact or energy-absorbing\n§ 173.306(f)(4). Such gas springs also are not subject to the International Civil\nAviation's (ICAO) Technical Instructions provided they meet the Technical Instruction's\ncriteria in Special Provision A114. The HMR authorizes the use of the ICAO Technical\nInstructions with certain exceptions as an alternative to the HMR, but does not authorize\nthe use of the IATA Dangerous Goods Regulations. For questions regarding the use of\nthe IATA Dangerous Goods Regulations, we suggest you contact the organization at\n514/390-6770.\nI hope this information is helpful. Please contact this office should you have additional\nquestions.\nSincerely,\nHattie L. Mitchell\nOffice of Hazardous Materials Standards\nChief, Regulatory Review and Reinvention\n173.306 f) 4)\n060142\n\n<<<PAGE 2>>>\n\nJun-22-2006 02:49pm\nFrom-ASSOCIATED SPRING RAYMOND\n4198910419\nT-520 P. 001/001 F-136\nAssociated Spring\nAssociated Spring - Raymond\nRaymond\nBARNES\n1705 Indian Wood Circle\nGROUP INC\nMIntyre\nSuite 210\n3173.306\nPhone: 419-891-9292\nMaumee, OH 43537\nFax: 419-891-0419\nCompressed Gas\nJune 22, 2006\n06-0142\nOffice of Hazardous Material Standards\nWas Dingon, Dacof Transportation\nTo Whom It May Concer:\nRecently I had a conversation with Kurt from the Hazardous Materials Standards Office to clarify detail related to\nBlow I have listed the specific DOT detail for which we are altempting to receive the interpretation against.\n173.306(D(4)\nabsorbing devices arc not subject to the requirements of this subchapter provided each:\n(4) Accumulators intended to function as shock absorbers, struts, gas springs, pneumatic springs or other impact or energy-\n173.306(D(4)(i)\ncapacity expressed in L and charge pressure expressed in bars does not exceed 80 (for example, 0.5 L gas space and 160 bar\n(i) Has a gas space capacity not excecding 1.6 L and a charge pressure not exceeding 280 bar, where the product of the\n173.306(D)(4)(ii)\ncharge pressure);\nand 5 times the charge pressure for products greater than 0.5 L gas space capacity;\n(ii) Has a minimum burst pressure oi 4 times the charge pressure at 20°C for products not excecding O.5 L gas space capacity\n173.306(f)(4)(iii)\ndegradable seal or other pressure relief device, such that the article will not fragment and that the article does not rocket; and\n(iii) Design type has been subjected to a fire test demonstrating that the article relieves its pressure by means of a fire\n173.306(f)(4)(iv)\nburst strength, burst mode and performance in a fire situation as specified in paragraphs (f(4)(i) through (f)(4)(iil) of this\n(iv) Accumulators must be manufactured under a written quality assurance program which monitors parameters controlling\nsection. A copy of the quality assurance program must be maintained at each facility at which the accumulators are\n173.306(D(5)\nmanufactured.\ntransported subject to the approval of the Associate Administrator.\n(5) Accumulators not conforming to the provisions of paragraphs (D)(1) through (f) (4) of this scction, may only be\nthat all product can ship via ground transportation with no special tags such as Non-Flammable or Hazardous Material.\nOur current product meets and has been tested against all items as they have been identified. Therefore we understand\nShipping via air will still require proper coding (UN1066), labeling (Non-Flammable) and the proper hazardous papcrwork to\nbe compliant with TATA standards for air transportation. Your prompt response on this matter is appreciated\nPlease conract me with any questions the DOT might have.\nThomas J. Fischer\nSinccrely\nProduct /Quality Engincer\nAssociated Spring Raymond","truncated":false,"body_characters":4532}