Chain & Packaging 3M Materials Resource Division — Hazardous Materials Safety Interpretation

Page 1U.S. Department 00 New Jersey Ave. S of Transportation ashington DC 205 Materials Safety Pipeline and Hazardous OCT 19 2007 Administration Mr. David D. Neitzel Ref. No. 07-0119 Specialist - MRD Supply Chain & Packaging 3M Materials Resource Division 3M Center, Bldg. 223-6S-04 St. Paul, MN 55414-1000 Dear Mr. Neitzel: stamping and approval of Multiple-element gas containers (MEGC) under § 178.74 of the This is in response to your request for a clarification of the requirements applicable to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, your inquiry concerns allowable pressure receptacle specifications fitted within a MEGC framework manufactured in the United States after January 1, 2007. In the scenario provided in your letter, you state that a MEGC has an attached data plate displaying both the United Nations (UN) stamp and the "USA" mark, and that the MEGC has been approved by an Independent Inspection Agency (IIA). Your questions are paraphrased and addressed as follows: Q1. Can the MEGC described above be fitted with dual stamped and approved DOT- and "USA" markings. Additionally, this arrangement has not been previousl T/ISO 11120 pressure receptacles that are not additionally stamped with the "UN' approved by the Associate Administrator as an "Alternative Arrangement." Al. The answer is no. In accordance with § 178.71(o), the UN symbol and the mark of the country where the approval is granted must be marked on each UN pressure transported to, from, or within the United States must be marked with "USA" as a country of approval in conformance with §§ 178.69 and 178.70. This requirement 171.8 178.74 178.11(0) 070119#

Page 2Does the definition of a multiple-element gas container specifically prohibit the use DOT specification cylinders or tubes within a MEGC. A2. The definition of a "multiple-element gas container," in § 171.8, references "UN cylinders, tubes, or bundle of cylinders." DOT specification cylinders or tube are not included. I hope this information is helpful. Sincerely, Thats Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 33M General Offices Foster • §178.503 §171.8,8178.74 Markings ЗМ June 6, 2007 07-0119 Mr. Edward T.Mazzullo Director, Office of Hazardous Materials Standards 2nd Floor PHH-10 U.S. DOT/PHMSA Washington DC 20590-0001 1200 New Jersey Avenue SE Subject: Request for Interpretation Concerning Stamping and Approval of MEG's Dear Mr. Mazzullo: I am requesting a written interpretation concerning allowable pressure receptacle specifications fitted within a MEGC framework manufactured in the United States after January 1, 2007. The MEGC has an attached dataplate displaying both the UN stamp of approval and the "USA" mark, and has been IIA approved. Specifically, I am requesting clarification if such an MEGC may be fitted with dual tamped and approved DOT-3T/ISO 11120 pressure receptacles which are no dditionally stamped with the UN stamp of approval and the "USA" mark if thi arrangement has not been previously approved by the Associate Administrator as an Alternative Arrangement. In addition, I am also requesting clarification if the definition for a "multiple-element gas container" as written in 49CFR § 171.8 specifically prohibits the use of DOT specification cylinders or tubes" within a MEGC:#

Page 4Thank you for your consideration of this request. Regards, Specialist - MRD Supply Chain & Packaging David D. Neitzel 3M Materials Resource Division St. Paul, MN 3M Center, Bldg. 223-6S-04 55144-1000 ddneitzell@mmm.com 651-737-7635 Fax 651-733-7152 Phone#