{"operation":"document","citation":"10-0123","title":"Cart, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-07-08","effective_on":null,"summary":"10-0123 response to Cart, Inc. concerning 173.202, 173.301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0123.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0123.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0123","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100123.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave, SE\nWashington, D.C. 20590\nPipeline and Hazardous Materials\nSafety Administration\nJUl - 8 L01lJ\nMr. Sam Cook\nProduct Manager\nCart, Inc.\n1300 Airport Drive\nBallground, GA 30107\nRef. No.: 10-0123\nDear Mr. Cook,\nThis letter responds to your June 8, 2010 email regarding the transport oflive fish under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you request\nconfirmation on the use of DOT 4L cylinders to continuously feed tanks containing live fish.\nAs provided by § 173.302(c), an authorized cylinder containing oxygen continuously fed to tanks\ncontaining live fish may be offered for transportation and transported in accordance with the\nHMR. Cylinders containing non-liquefied compressed oxygen must be offered for transport in\naccordance with the requirements of §§ 173.301, and 173.302. Refrigerated liquefied oxygen\nmust be offered for transport in accordance with the requirements of § 173.316. Authorized\ncylinders containing oxygen, refrigerated liquid, used to supply oxygen to tanks for the transport\nof live fish, are considered an integral part of a process system and are excepted from the HMR\nunder 173.320(b)(2).\nI hope this answers your inquiry. If you have further questions, please do not hesitate to contact\nthis office.\nCharles E. Betts\n~f, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nLea V\"l{\nprakeford, Carolyn (PHMSA) EkceOlons\n~1'30~O\n,\nFrom: INFOCNTR (PHMSA) JO-o/Z3\nSent: Tuesday, June 08,20103:31 PM\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: Request for a formal letter of interpretation\nCarolyn,\nThanks,\nRob\nA request for a formal written letter of interpretation.\nFrom: COok, Sam [mailto:Sam.COok@chartindustries.com]\nSent: Tuesday, June 08, 20102:43 PM\nTo: INFOCNTR (PHMSA)\nCc: Carey, Tom; Haukoos, Bill\nSubject: Request for a formal letter of interpretation\nTo whom it may concern,\nBased on a conversation that I had this morning with I\\leal, one of your Transportation Specialist, I am requesting a\nformal letter of interpretation regarding the use of DOT 4L liquid cylinders for the transportation of live fish. The live fish\nare placed inside of large contained trailers and the liquid cylinders are used to bubble oxygen gas into the water to\nkeep the fish alive during transit. It varies by customer, but from our experience this application is serviced by both our\nmedium (MP) and high pressure (HP) liquid cylinders. The typical sizes are our 160 and 180 liter sizes. The normal\noperating pressure for the MP cylinders is 125 psi and for the HP cylinder that pressure is 300 psi. Final line regulators\nare used in both cases to reduce the trailer pressure to approximately 30 psi. This low pressure oxygen feeds a manifold\nwith multiple legs to make sure that the oxygen gas is \"bubbled\" evenly throughout the trailer bed. The cylinders are\nsecured to the trailer frame and labeled based on the guidelines of CFR 49.\nIn addition to Neal, I have spoken with several other Transportation Specialists that were familiar with our DOT 4L liquid\ncylinders and the live fish transport application. There is general agreement that this is a \"legal\" use of DOT 4L cylinders\nbased on CFR 49 section 173.320 (B)(2) which states:\n(b) The requirements of this sub-chapter ( section 173 ) do not apply to atmospheric gases and helium:\n(2) When used in operation of a process system; such as a refrigeration system ( pressure may exceed\n25.3psig ).\nEven though we are not strictly obligated as a company to ensure that our customers are using our DOT 4lliquid\ncylinders in DOT approved applications, we would like to help educate our them regarding the DOT's position regarding\nthis application. This will help ensure that the equipment is installed and operated correctly and safely. A formal letter of\ninterpretation is the important first step in starting this dialog. If you have any questions regarding this request, please\ncontact me using the info listed below. Thanks for your cooperation in this matter.\nSam Cook\nProduct Manager, D&S SPV\nChart Inc.\n1300 Airport Drive\nBallground, GA 30107\nOffice: 770-720-6729\nCell: 404-643-3681\nE-mail: sam.cook@chart-ind.com\n1","truncated":false,"body_characters":4229}