Amex Int'l, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 FEB 2 0 2013 Mr. Arlee Mueller Amex Int'l, Inc. I 030 Lone Oak Road, Suite 130 Eagan, MN 55121 Ref. No.: 13-0012 Dear Mr. Mueller: This responds to your January 8, 2013 letter concerning the transportation by vessel of accumulators installed in assembled machinery. Specifically, you ask whether the International Maritime Dangerous Goods (IMDG) Code provides an exception similar to that which is found in§ 173.306(f)(l) ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Section 173.306(f)(l) specifies that accumulators which are installed in motor vehicles, construction equipment, and assembled machinery and designed and fabricated with a burst pressure of not less than five times their charged pressure at 70 °F, when shipped, are not subject to the requirements ofthe HMR. The IMDG Code does provide a similar exception for accumulators under Special Provision 283 in paragraph 3.3.1. Special Provision 283 specifies that articles containing gas, intended to function as shock absorbers, including impact-energy-absorbing devices or pneumatic springs, are not subject to the provisions of the IMDG Code provided:(!) each article has a gas space capacity not exceeding I .6L and a charge pressure not exceeding 280 bar where the product of the capacity (liters) and charge pressure (bar) does not exceed 80; (2) each article has a minimum burst pressure of 4 times the charge pressure at 20 oc for products not exceeding 0.5L gas space capacity and 5 times charge pressure for products greater than 0.5L gas space capacity; (3) each article is manufactured from material which will not fragment upon rupture; ( 4) each article is manufactured in accordance with a quality-assurance standard acceptable to the competent authority; and (5) the design type has been subjected to a fire test demonstrating that pressure in the article is relieved by means of a fire-degradable seal or other pressure relief device, such that the article will not fragment and that the article does not rocket. While Special Provision 283 in the IMDG Code is not identical to the exception provided in 173.306(£)(1) of the HMR, it does provide a similar exception for accumulators. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2PACKING-DOCUMENTATION-CONSULTING N ttkel_s cj 173' '30 to(f)(L) Accumu JafoKs l 5 -tJ0/7-J US Department of Transportation Pipeline and Hazardous Materials Safety Administration Office of International Standards East building/PHH-70 1200 New Jersey Ave, S.E. Washington, D.C. 20590 January 8, 2013 Subject: Accumulators installed in assembled machinery being transported by vessel Dear Sir or Madam, Upon viewing the IMDG Code, Special Provision 283, in regards to the transport of accumulators classified as UN3164, ARTICLES, PRESSURIZED, PNEUMATIC or HYDRAULIC, I do not see any specific exception shown for articles that are installed in assembled machinery that is similar to the exception shown in 49 CFR, 173.306(f)(1 ). Am I correct in assuming that there is no exception for articles that are installed in assembled machinery when being transported in accordance with the IMDG Code? Sincerely, ,1 // (;:4 /l'UL Arlee Mueller President Amex lnt'l, Inc. 1 030 Lone Oak Road Suite 130 Eagan, MN 55121 Tel: 651-683-9981 Fax: 651-683-9983 Email: arlee@tracarsvc.com#