Line Pressures, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE 2.1 2007 Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration Mr. Paul Graves Ref. No.: 07-0028 3900 South Lipan Street Line Pressures, Inc. Englewood, Colorado 80110-4422 Dear Mr. Graves: This is in response to your January 19, 2007 letter requesting clarification of the Hazardous refrigerated liquefied gases. Your questions are paraphrased and answered below. Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the transportation of Q1. Does the HMR, as amended on December 29, 2006 (71 FR 78627), require orientation markings to be placed on a DOT 3-series cylinder containing Nitrous oxide? Would a DOT 4L cylinder containing Nitrogen, refrigerated liquid be considered an "open cryogenic receptacle"? Al. The answer is no to both questions. Section 172.312(a) requires each non-bulk package Q2. Is a pressure relief device considered to be a vent? A2. The answer is no. The term "vent" as used in § 172.312(a) applies to non-bulk packages other than cylinders. Q3. If "20 cylinders" and an additional "20 cylinders" of a different size containing the same hazardous material are offered into transportation, would it be correct to enter the total quantity of hazardous materials on the shipping paper as "40 cylinders". A3. The answer is yes. Section 172.202(a)(5) requires the total quantity of hazardous volume, or by activity for Class 7 (radioactive) materials and must include an indicatio naterials covered by the description to be indicated on a shipping paper (by mass o of the applicable unit of measurement for example, "200 kgs." or "50 L." However, this requirement is not applicable to cylinders, provided some indication of the total quantity such as "40 cylinders" as used in your example above. 171.8 172•202 142.312 (a) 070028#

Page 2this office. I hope this information is helpful. If you have further questions, please do not hesitate to contact Sincerely, Have Batt Santa resportion special sue Office of Hazardous Materials Standards#

Page 3Merrera LINEPRESSURE 372. 202 //.. : $172.312 January 19, 2007 Shipping Papers / Markings 07-0028 United States Department of Transportation Mr. Charles Betts, Sr. Transportation Regulations Specialist Pipeline and Hazardous Materials Safety Administration 400 7' Street S.W. Office of Hazardous Materials Standards, PHH-10 Washington, DC 20590-0001 RE: Docket No. PHMSA-06-25476 (HM-215I) Final Rule Federal Register publication dated December 29, 2006 Dear Mr. Betts: Line Pressure, Inc. submits this request for clarification in regards to certain revisions to the Hazardous Materials Regulations (HMR) published in the Federal Register on December 29, 2006 Section 172.312 of 49 CFR, paragraph (a) is amended to read "requiring orientation markings on of refrigerated liquefied gases." Currently, the terms "pressure relief device" and "vent" are used single packagings fitted with vents and on open cryogenic receptacles intended for the transport in 49CFR § 173.316(a)(7) in regards to relieving pressure of a cryogenic liquid in cylinders. My 172.312 require orientation markings on DOT-3 series cylinders containing Nitrous Oxide? As concern is for the definition of the term "VENT". As amended, does the new wording for 49CFR § example, a 3AA-2015 cylinder filled with 50 pounds of Nitrous Oxide product would be considered pressure relief device. Does this pressure relief device qualify as a vent? non-bulk package containing liquid hazardous material fitted with an appropriate Line Pressure, Inc. is interpreting the meaning of an "open cryogenic receptacle" as referring to Refrigerated Liquid. These containers are usually contain 5, 10, 20 or 25 liters or product and small laboratory containers typically used for the storage or transportation of Nitrogen, contain a small cap (lid) with a protrution which simply rests on top the opening of the container. a DOT-4L series cylinder as an open cryogenic receptacle because of the valves located on the Upon consulting with other professional medical gas suppliers and manufacturers, one referred to Section 172.202(a)(5)(1)(B) of 49 CFR excepts cylinders "provided some indication of the total quantity is shown, for example, 10 cylinders." cylinders of one size and 20 cylinders of a different size are loaded on a transport vehicle which, Line Pressure interprets this to mean if 20 40 cylinders for the proper shipping name describing the hazardous material being transported. contain the same hazardous material, the proper entry on the shipping paper would be to show Would this entry be correct in this situation? advances being made for the safe transportation of hazardous materials in commerce Thank you in advance for your time and response to our clarification request. We support the continued Paul trans Paul Graves Line Pressure, Inc. Medical Gas/Specialty/Cryogenic Analgesia Sedation/Respiratory Care Precision Delivery Systems Englewood, Colorado 80110-4422 3900 South Lipan Street 303-742-0202 800-783-1GAS#