Hazardous Control Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Depmtment of Transportation Pipeline and Hazardous · Materials Safety Administration JUL 1 7 2012 1200 New Jersey Avenue SE Washington. DC 20590 Ms. Nina Ximena Artime Hazardous Control Inc. 8600 NW 72 Street Miami, FL 33166 Ref. No. 12-0076 Dear Ms. Artime: This responds to your March 20, 2012 request for clarification regarding the transportation by vessel of compressed oxygen under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask ifyou are required to package cylinders containing "UN 1072, Oxygen, compressed, 2.2, 5.1" in an outer package that meets the "DOT31 FP" specification. The answer to your question is no. In accordance with§§ 173.302(t) and 173.304(t) compressed oxygen and oxidizing gases transported by aircraft must meet certain requirements. Specifically, these requirements include placing the cylinder in a rigid outer packaging meeting the requirements of§§ 173.302(t)(3) and 173.304(t)(3) respectively. The requirements in§§ 173.302(t) and 173.304(t) are applicable to shipment of compressed oxygen by aircraft, not by vesseL I hope this answers your inquiry. If you need further assistance, please contact this office at (202) 366-8553. Sincerely, Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Cc: Subject: Edmonson, Eileen (PHMSA) Tuesday, March 20, 2012 3:49PM Lawson, Eleanor (PHMSA) Drakeford, Carolyn (PHMSA) RE: UN1072- Ocean transport clarification From: hazardous-control@hotmail.com [mailto:hazardous-control@hotmail.com] On Behalf Of HAZARDOUS CONTROL Sent: Tuesday, March 20, 2012 3:29 PM To: Lawson, Eleanor (PHMSA) Subject: UN1072- Ocean transport clarification Good day Eleanor, I hope everything is going well with you, again I need your help with some HAZMAT question. I need to ship by ocean in a full container 1 Box- UN1072, my question is: Do we need package in an outer package that meets the DOT31 FP specification? Cylinders containing Oxygen, compressed, UN 1 072; Compressed gas, oxidizing, n.o.s., UN 3156; Liquefied gas, oxidizing, n.o.s., UN 3157; Nitrogen trifluoride, UN 2451; or Nitrous oxide, UN 1070 must be packaged as required by 49 CFR 173.302(f) and 173.304(±) and be placed in a rigid outer packaging that meets specified flame penetration and them1al resistance requirements as prescribed in Appendices D and E of 49 CFR Part 178. This requirement does not apply to cylinders containing medical-use compressed oxygen transported in accordance with US Variation 15. Thanks a lot for your continuous support. Wishing you a very happy Saint Patrick's month, full of good luck! Thanks for choosing Hazardous Control as your company for all your HazMat needs! Safe and prevention is our principal goal! Nina Ximena Artime (786) 353 2t<::O . Fax (786': :mo OLJ4 . 24 Hr. Ernerqency 8600 NVV 72 ST, Miami, FL TH66 P.OSox S22013, i'lia:ri, FL 33152 :::1na:l: customerservice@hazardouscontrol.com >1,;n: hazardous-control@hotmail.com at: W.\"ty'!,br?9CdQ\J$CoD1rnL_c;qm 1#