John Deere TCAO — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Administration Materials Safety JAN 1 3 2016 Mr. Brad Storm Hazardous Materials Specialist John Deere TCAO 3500 E Donald St Bldg 6011 ESB-2 373 Waterloo, IA 50703 Ref. No. 15-0179 Dear Mr. Storm: This responds to your August 24, 2015 request for clarification pertaining to accumulators under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether an accumulator in a "hydraulic system used to maintain constant pressure, build pressure gradually and store energy" is eligible for the exception in § 173.306(f)(4) provided the accumulators otherwise meet the requirements in § 173.306(f)(4)(i) to (iv) of the HMR. The requirement in § 173.306(f)(4) applies to accumulators intended to function as shock absorbers, struts, gas springs, pneumatic springs or other impact or energy-absorbing devices. Based on the information contained in your letter, the accumulators are not intended to function in any of these capacities and would therefore not be eligible for this exception. However, it should be noted that other exceptions for accumulators are provided in § 173.306(f)(1), (2), (3), and (5). I hope this satisfies your request. Sincerely, FAnn Faster T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Lehman 5173. 306(F) Lunited Quarties Dodd, Alice (PHMSA) 15-0179 From: Geller, Shelby CTR (PHMSA) Sent: To: Monday, August 24, 2015 3:00 PM Hazmat Interps Subject: FW: Clairification on 49CFR 173.306(f) Dear Shante and Alice, Please see the below request for a formal letter of interpretation. I spoke with Mr. Storm. Thanks, Shelby From: Storm Bradley B [mailto:StormBradleyB@JohnDeere.com] Sent: Monday, August 24, 2015 9:57 AM To: PHMSA HM InfoCenter Subject: Clairification on 49CFR 173.306(f) To: PHMSA Hazardous Materials Information Center Accumulators are used in Deere equipment hydraulic systems to; absorb shock, maintain constant pressure, build pressure gradually and to store energy. When an accumulator is manufactured to the safety requirements of 49CFR173.306(f)(i),(ii),(iii) and (iv), but is used in the hydraulic system to maintain constant pressure, build pressure gradually and store energy qualify for the 49CFR173.306(f) (4) exception? Accumulators (Articles, pressurized pneumatic or hydraulic containing non-flammable gas. The following applie (f) accumulators, which are hydraulic accumulators containing nonliquefied, nonflammable gas, and nonflammable liquids o pneumatic accumulators containing nonliquefied, nonflammable gas, fabricated from materials which will not fragment up (4) absorbing devices are not subject to the requirements of this subchapter provided each Accumulators intended to function as shock absorbers, struts, gas springs, pneumatic springs or other impact or energy- (i) expressed in liters and charge pressure expressed in bars does not exceed 80 (for example, 0.5 L gas space and 160 ba Has a gas space capacity not exceeding 1.6 L and a charge pressure not exceeding 280 bar, where the product of the c (i) chas a presume burst pressure of 4 times the charge pressure at 20 °C for products not exceeding 0,5 L gas space capa (ii) (iv) Accumulators must be manufactured under a written quality assurance program which monitors parameters controlling strength, burst mode and performance in a fire situation as specified in paragraphs (f(4)(i) through (f)(4) ii) of this sectic#

Page 3Regards, Brad Brad Storm Hazardous Material Specialists John Deere TCAO 3500 E Donald St Waterloo, IA 50703 Bldg 6011 ESB-2 373 'Cell 319-488-6891 CONFIDENTIALITY. This message, including attachments, may be confidential. If you believe the message was sent to you in error, recipient, retention, dissemination, distribution, or copying of the communication is strictly prohibited. Thank you do not read the contents and please reply to the sender that you have received the message in error. If you are not the intended 2#