{"operation":"document","citation":"07-0127","title":"Hazardous Materials Transportation Engineer — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-07-26","effective_on":null,"summary":"07-0127 response to Hazardous Materials Transportation Engineer concerning 173.219.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0127.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0127.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0127","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070127.pdf","body":"<<<PAGE 1>>>\n\n.S. Departmen\nf Transportatio\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nAdministration\nHazardous Materials safety\nJUL ? 6 2007\nMr. Jerry A. Shipman, MT-230\nHazardous Materials Transportation Engineer\nRef. No.: 07-0127\nCaterpillar Inc.\n500 North Morton Avenue\nMorton, IL 61550-0474\nDear Mr. Shipman:\nThis is in response to your June 25, 2007 letter requesting clarification of the requirements\nin the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to life-\nsaving appliances. Specifically, you ask if § 173.219 requires a package that contains a\nself inflating life-saving appliance and hazardous materials authorized by § 173.219(b) to\nnot self inflating,\" or only \"Life-saving appliances, self inflating.\"\nbe marked with both \"Life-saving appliances, self inflating\" and \"Life-saving appliances,\nA life-saving appliance typically contains small quantities of hazardous materials that are\nrequired for the appliance to be effective during use (§ 173.219(b)). For example, a self-\ninflating life vest used by boaters may contain flares and compressed oxygen; a non-self\ninflating survival kit used by hikers may contain strike-anywhere matches, electric storage\nappliances; however, they may be used to supplement an instrument or device that is\nbatteries, and bear repellant. Hazardous materials cannot stand alone as life-saving\ndesigned to assist those in distress.\nIn accordance with the HMR, the description \"Life-saving appliances, self inflating,\nUN2990\" applies to self-inflating appliances and \"Life-saving appliances, not self\ninflating, UN3072\" applies to life-saving appliances that do not self inflate. The\nto supplement the appliance, such as those listed in § 173.219(b). Therefore, a life-saving\ndescriptions apply to the overall appliance rather than individual hazardous material used\nappliance that is self-inflating and contains hazardous materials in addition to those\nrequired for self inflation (see above for example of self-inflating life vest) would be\nassigned the proper shipping name \"Life-saving appliances, self inflating.\"\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nChief, Standards Development\n*aterials Standards\n173.219(6)\n070127\n\n<<<PAGE 2>>>\n\nSupko\nPage 1 of 1\n$13.219(b)\nDrakeford, Carolyn <PHMSA>\nLite-saving.\nFrom: INFOCNTR <PHMSA>\n07-612 Ppliance\nSent: Monday, June 25, 2007 12:37 PM\nTo:\nDrakeford, Carolyn <PHMSA>\nSubject: FW: packing instruction 173.219\nSent: Thursday, June 21, 2007 1:18 PM\nFrom: Jerry A. Shipman [mailto: Shipman_Jerry_A@cat.com]\nTo: INFOCNTR <PHMSA>\nSubject: packing instruction 173.219\nI have gotten various answers as to the interpretation as to how this rule reads. First and far most / was\nI have contacted various individuals within the DOT, Hazardous Materials Safety Administration and\nhazard of the hazardous materials, in relationship to packing instruction 173.219 life-saving appliances\nunder the assumption that the proper shipping name and/or hazard class labels are to communicate the\nself-inflating hazard without using both proper shipping names. I only have to use the self-inflating proper\nthis is not the case so I am told by PHMSA. I am told that I can include a not self-inflating hazard in with a\nmust mark my package with both proper shipping names. I have not found in the regulations were it\nshipping name and this covers my not self- inflating hazards, but If I ship Paint and Paint related material |\nA self-inflating and not self-inflating in one package I need to mark the package with both proper shipping\nallows me not to mark the package to communicate all hazards with in the package. I thought that if I had\nshipping names.\nnames as I would have to do for Paint And Paint related material, thus the reason for both proper\nappliances (class 9), There are signal devices which are 1.4G, these when shipped as signal devices are\nProblem number 2a, 173.219 allows for signal devices (class 1) to be included in life-saving\nforbidden on passenger aircraft. When shipped under 173.219 as life-saving appliance (class 9) they can\nbe placed on a passenger aircraft. These signal devices represent a not self-inflating hazard\nmust be an integral part of the appliance. Meaning that the appliance can not operate properly without the\nProblem number 2b, I am told that even though the regulations state that the hazardous material\nhazardous material. I can include such signal devices into self-inflating appliances such as life-vests and\nlife rafts without including my second proper shipping name. 173.219(b)(6) states that for self-inflating life\nunder the assumption that this is the only explosive that would be permitted to be packed with a self-\nsaving appliances only cartridges of division 1.4S, for the purpose of the self-inflating mechanism. I was\ninflating appliance as long as it is used to inflate the appliance. self-inflating appliance only apply to\ninflating hazards is accidentally activated. If it is OK to include not self-inflating appliances in with self-\nappliances were the hazard is if it accidentally inflates. my question is what happens when one not self-\ntypes of life saving appliances if this is OK why don't we just use the proper shipping na. ne life-saving\ninflating appliance and not communicate the hazard of the not self-inflating, why do we need two different\nappliances.\nIf there are any questions regarding the information contained in this email please contact me.\nThank You,\nHazardous Materials Transportation Engineer\nJerry A. Shipman\nCell: (309) 256-0003\nOffice: (309) 266-3932\nEmail: Shipman_Jerry_A@cat.com\n6/25/2007","truncated":false,"body_characters":5665}