{"operation":"document","citation":"11-0111","title":"Marv Golden Pilot Supplies — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-06-21","effective_on":null,"summary":"11-0111 response to Marv Golden Pilot Supplies concerning 173.219.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0111.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0111.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0111","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110111.pdf","body":"<<>>\n\nU.S. Department 1200 New Jersey Avenue SE\nof Transportation Washington. DC 20590\nPipeline and Hazardous\nMaterials Safety\nAdministration JUN 2 12011\nMr. Richard Golden\nMarv Golden Pilot Supplies\n8690 Aero Drive, Suite 102\nSan Diego, CA 92123\nRef. No.: 11-0111\nDear Mr. Golden:\nThis responds to your May 9, 2011 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment oflifesaving\nappliances. In your letter, you state that your company would like to ship twenty\npounds or less of \"UN2990, Life-saving appliances, self inflating, 9\" by ground\ntransportation. You indicate that these materials do not contain any hazardous materials,\nother than the small carbon dioxide cylinders that are required as part of the life-saving\nappliance. You specifically ask whether your materials, as described above, are eligible to\nutilize the exception provided § 173.219(c)(5).\nSection 173.219( c)(5) specifies that, for other than transportation by aircraft, life saving\nappliances containing no hazardous materials other than carbon dioxide cylinders with a\ncapacity not exceeding 100 cm3 are not subject to the provisions of the HMRprovided they\nare overpacked in rigid outer packagings with a maximum gross mass of 40 kg. Therefore,\nprovided your shipment meets all the requirements in § 173.219(c)(5), it would be eligible\nto utilize this exception.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n~~~~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\nDra~eford, Carol\nFrom: INFOCNTR (PHMSA)\nSent: Thursday, May 12, 2011 12:48 PM\nTo: Drakeford, Carolyn (PHMSA)\nSubject: FW: Hazmat Information Center Feedback: Shippers-General Requirements for Shipments\nand Packagings (Sections 173.1 – 173.476)\nHi Carolyn,\nWe received the attached letter at the HMIC. The caller previously spoke with Adam Lucas.\nThanks,\nVictoria\nVictoria Lehman\nHazmat Information Center (HMIC)\nhttp://phmsa.dot.gov/hazmat/info-center\n(202) 366-1035\n-----Original Message----From:\nPHMSA-Feedback [mailto:PHMSA-Feedback]\nSent: Monday, May 09, 2011 4:17 PM\nTo: PHMSA HM InfoCenter; PHMSA Webmaster\nSubject: Hazmat Information Center Feedback: Shippers-General Requirements for Shipments and\nPackagings (Sections 173.1 – 173.476) .\nI would like to receive a ruling on shipping small quantities under 20 pounds of Inflatable\nLife Vests via Ground Shipping in the domestic U.S. These technically come under the\nfollowing classification because they have small C02 cartridges:\nLifesaving Appliances - Self Inflating UN2990 Class 9\nThe manufacturer has informed me that via Ground there is no special shipping or HAZMAT\nrequirement at all and they ship these all the time. If they ship via air or in large\nquantities, it requires HAZMAT handling.\nI spoke to a person at the USDOT who cited 49CFR 173.219, specifically c5 and stated that «if\nthe C02 cylinders themselves are less than 100cm cubed each, and have a rigid outer\npackaging, with gross mass under 40 kilograms, this would be not be considered Hazmat.\"\nYet another person at the DOT stated that I would have to have some special shipping papers\nin the box, but did not indicate what those papers would need to state.\nPlease advise as to my requirements in these matters. Thank you very much.\nRicha:rd Golden\nMarv Golden Pilot Supplies\n8690 Aero Drive, Suite 102\nSan Diego, CA 92123\nrick@marvgolden.com\n800-348-0014\nName: Richard Golden\nOrganization: Marv Golden Pilot Supplies\n1\n\n<<>>\n\nEmail: rick@marvgolden.com\nAddress: 8690 Aero Drive, Suite 102\nCity: San Diego\nZip Code: 92123\nPhone: 800-348-0014\n2","truncated":false,"body_characters":3735}