Airgas-SAFECOR — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAR 0 3 2018 Mr. John Anderson Airgas-SAFECOR P.O. Box 20067 Cheyenne, WY 82003 1200 New Jersey Avenue, SE Washington, D.C. 20590 Reference No. 08-00 18 Dear Mr. Anderson: This is in response to our January 15,2008 telephone conversation and your e-mail concerning the entry "Chlorodifluoromethane or Refrigerant Gas R 22,2.2 (non-flammable gas), UN 101 8" appearing in the tj 172.101 Hazardous Materials Table (HMT; 172.101) of the Hazardous Materials Regulations (HMR). The HMT lists "Chlorodifluoromethane" and "Refrigerant Gas R 22" in Roman type. You state your company receives the material from different vendors in packages marked with either proper shipping name. You ask if your company's shipping paper may display both proper shipping names or if it must display only one. When one proper shipping name includes alternative wording choices that appear in Roman type in a sequence and are separated by the word "or" in italics, such as "Articles, pressurized pneumatic or hydraulic containing non-Jlammable gas," it is the intent of @ 172.10 1. (c)(2) that Roman type wording choice that appropriately describes the material, e.g., pneumatic or hydraulic, must be used. However, in your scenario, both Roman type names describe the same material. Therefore, it would be permissible to show the proper shipping name as "Chlorodifluoromethane or Refrigerant gas R22." I hope this satisfies your request. If you have any further questions, please contact this office at (202) 366-8553. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2B Page 1 of 1 Drakeford, Carolyn <PHMSA> From: Mitchell, Hattie cPHMSA> Sent: Tuesday, January 15,2008 7:29 AM To: Drakeford, Carolyn <PHMSA> Subject: FW: Proper shipping name description on a hazardous material shipping paper From: John Anderson (SAFECOR) [mailto: John.Anderson.SAFECOR@Airgas.com] Sent: Monday, January 14,2008 3:35 PM To: Mitchell, Hattie <PHMSA> Subject: Proper shipping name description on a hazardous material shipping paper Good afternoon, Per our phone conversation this afternoon, would the following description be acceptable. Chlorodifluorornethane or Refrigerant Gas R22 2.2 UN1018 Our question is can we both descriptions (Chlorodifluoromethane or Refrigerant Gas R22) or are we only allowed to use one? If you would prefer this question as an actual letter instead of an email, please let me know. John Anderson Airgas-SAFECOR P. 0 . Box 20067 Cheyenne, WY 82003 Phone 1-307-778-8809 Fax 1-307-778-7497 john.anderson@airgas.com#