Guidanceguidance
09-0223
Hydrotest Tech. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 JAN - 5 2010 Mr. David A. Wright Fire Extinguisher/ DOT Cylinder Hydrotest Tech. Building 1745 1 st A venue NAS Corpus Christi, TX 78419 Ref. No.: 09-0223 Dear Mr. Wright: This responds to your facsimile letter regarding the correct identification number under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for a shipment of fully charged "Amerex Model 600, Halon 1211 Flightline Wheel Units" from NAS in Corpus Christi, Texas to JRB in Fort Worth, Texas. According to your letter, "Flightline Wheel Units" are DOT 4BW240 specification cylinders, maintained by your organization, and placarded with the identification number "UN1956" (containing Halon 1211 + N2). The MSDS uses the identification number "UN 1974." You ask for guidance in determining the correct identification number to use to ship these cylinders. You did not provide sufficient information (e.g., hazard characteristics, MSDS, etc.,) on your product to enable us to make a determination regarding classification. Under 49 CFR 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office does not perform that function. Under the HMR, the UN numbers "UN1956" and "UN1974" are the identification numbers for the descriptions "Compressed gas, n.o.s., 2.2", and "Chlorodifluorobromomethane, 2.2" or "Refrigerant gas, R 12B 1", respectively. The HMR specify requirements for classification, packaging, preparation of shipping papers, marking, labeling, placarding, emergency response information, and training. The definition and packaging requirements for compressed gases are found in 49 CFR 173.115 and 173.302,#
Page 2respectively. A list of commercial suppliers ofthe HMR is enclosed. You may also access the HMR at www.gpoaccess.gov/ecfr. I hope this infonnation is helpful. Ifwe can be of further assistance, please contact us . S.incere~y, ~ ~ ! #f4lt~ b . har1eS E. Betts Chief, Standards Development ~ce of Hazardous Materials Standards Enclosure#
Page 3Drakeford. Carolyn (PHMSA) From: Foster, Glenn (PHMSA) Sent: Monday, September 28, 2009 3:20 PM To: Drakeford, Carolyn (PHMSA) Cc: Mitchell, Hattie (PHMSA) . ~/7Z./OI Subject: FW: UN1974/UN1956 Prpel' cah II 1'1-:J -()ZZ 3 ~q ~ngru~ -----Original Message----From: Cushmac, George (PHMSA) Sent: Monday, September 28, 2009 11:40 Al'1 To: Foster, Glenn (PHMSA) Cc: Mitchell, Hattie (PHMSA); 'david.a.wright2 .mil' Subject: FW; UN1974/UN1956 Glenn, Per our discussion, I am forwarding Mr. Wright's email message to you. This is an issue that should be resolved by the Office of Hazardous Materials Standards. Note that earlier today, Mr. Wright called the Information Center(?) and was transferred to me. Following my conversation with Mr. Wright, he sent an email message to me explaining his problem (see below) . Regards, George E. Cushmac, Ph.D. Office of Hazardous Materials Technology (PHH-20) Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation East Building, 2nd Floor (E21-221) 1200 New Jersey Avenue, S.E. Washington, DC 20590-0001 Tel: 202-366-4493 Fax: 202-366-3753 email: george.cushmac@dot.gov -----Original Message----From: Wright, David A CIV NAS CORPUS CHRISTI TX [mailto:david.a.wright2@navy.mil] Sent: Monday, September 28, 2009 10;43 Al'1 To: Cushmac, George (PHMSA) Subject: UN1974/UN1956 George, I am attempting to ship fully charged Amerex Model 600, Halon 1211 Flightline Wheel Units from here to JRB Fort Worth. These wheel units are DOT 4BW240 spec. cylinders. I have held maintenance on these units and as per regs. have placarded them as UN1956 (Halon 1211 + N2). All of the MSDS's that have been found use UN1974 in section 14 of the sheet which is the Transport Information Section. Supply Department will not ship because of the difference in UN numbers. Can you please me specific guidance? It seems to me that sense BOTH are division 2.2 gases they could be shipped under the division code. ViR David A. Wright Fire Extinguisher/DOT Cylinder Hydrotest Tech. BLDG. 1745 1st Ave. NAS Corpus Christi, Tx 78419 (361) 961-2870 DSN: 861-2870 "FOR OFFICIAL USE ONLY - PRIVACY SENSITIVE" 1#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.