Tracerco — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, DC 20590 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Administration APR 1 3 2018 Andrew Booton Operations Manager Tracerco 4106 New West Drive Pasadena, TX 77507 Reference No. 17-0096 Dear Mr. Booton: This letter is in response to your August 24, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities of compressed gas. You describe a scenario in which your facility will be shipping "UN1971, Natural gas, compressed" in U.S. Department of Transportation (DOT) 3E specification cylinders to your laboratories for analysis. Each cylinder will have a volume (meaning capacity) of less than 4 fluid ounces; will have a service pressure of 1,800 psi; and will be placed in hard-plastic cases with foam inners to meet the strong outer packaging requirements. We have paraphrased and answered your questions as follows: Q1. You ask if a shipment of approximately 20 cylinders in hard-plastic cases, with each case having a gross weight of less than 30 kg (66 pounds), would be excepted from the labeling and shipping paper requirements as prescribed in § 173.306. A1. Based on the scenario you provided, the subsequent phone conversation with a member of my staff regarding the clarification and meaning of the word "volume" versus "capacity," and the provisions found in § 173.306(a)(1), your shipment would be excepted from the labeling (unless the material is offered for transportation or transported by aircraft) and specification packaging requirements. The material must be packaged in containers meeting the capacity requirements of § 173.306(a)(1) of not more than 4 fluid ounces and the completed package may not exceed 30 kg (66 pounds) gross weight. Additional exceptions for limited quantities of compressed gas meeting (a)(1) are found in § 173.306(i) including exception from shipping paper requirement, if the package and transport meets the conditions in paragraph (i). Note, you are not required to use specification packaging (e.g., DOT 3E); however, if you choose to use this type of packaging as the container and represent it as a DOT 3E as qualified for transportation, you must adhere to the specification and continued service requirements for a DOT 3E cylinder. Otherwise, you must obliterate or cover the markings that indicate it is a DOT 3E cylinder qualified for transportation.#

Page 2Q2. You ask if § 173.306(a)(2) would be applicable to your packaging of "UN1971." A2. The requirements of § 173.306(a)(2) are for refillable metal containers that are filled with a material that is not classed as a hazardous material and then charged with a non- flammable (non-poisonous), non-liquefied gas. Based on the information you have provided, the material you have is a Division 2.1 flammable gas and, therefore, would not be eligible for § 173.306(a)(2). I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, )er Kindere Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Baker 5 | 73.306 Lumited Quarty Dodd, Alice (PHMSA) 17-0096 From: INFOCNTR (PHMSA) Sent: To: Thursday, September 14, 2017 10:47 AM Hazmat Interps Subject: FW: Letter of Interpretation Request regarding 49 CFR 173.306. Hi Alice, Please submit this as a letter of interpretation. I was not able to reach Mr. Booton via telephone or email to confirm he needed a written response to his questions. Please let me know if you have any questions. Thank you, Jodi From: Andrew Booton [mailto:Andrew.Booton@tracerco.com] Sent: Thursday, August 24, 2017 6:59 PM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Subject: Letter of Interpretation Request regarding 49 CFR 173.306. My request for interpretation is in regards to limited quantity shipments of compressed gases, flammable Class 2.1 As part of our operations we intend to ship by ground, compressed gas samples UN1971 Natural Gas (Hazard Class2.1) from various location across USA to our laboratory for analysis. We intend to use DOT-3E Specified Cylinders with a volume less than 4 fluid ounces with a service pressure of 1800psi. Approximately 20 cylinders with compressed gas (Flammable Typically UN1971) with internal pressure up to 1800 PSI would be placed in a hard plastic case that meets 49CFR 173 subpart B (strong outer packaging, with foam inner to provide stable support of the cylinders). With a gross weight of the package less than 30 KG. 1) Referring to 49 CFR 173.306 we believe that it is possible to ship this package by ground transport in limited quantities and be excepted from labelling requirements and not subject to shipping paper requirements but should show the limited quantity marking. Is this interpretation correct? 2) Does 49 CFR 173.306(a)(2) pertain to this type of shipment? If so in what ways? Your interpretation on this part would be helpful. Your responses to the above 2 question would be greatly appreciated. If you have any further questions for clarification please contact me by email or telephone. Regards Andrew Booton Operations Manager Tracerco Providing Insight Onsite Tracerco 4106 New West Drive Pasadena, TX 77507 1#

Page 4T: 281-291-7769 M: 281-682-2956 Andrew. Booton@tracerco.com www.tracerco.com If the reader of this email is not the intended recipients), please be advised that any dissemination, distribution or copying of this information is strictly prohibited. Johnson Matthey PLC has its main place of business at 5th Floor, 25 Farringdon Street, London (020 7269 8400). Johnson Matthey Public Limited Company Registered Office: 5th Floor, 25 Farringdon Street, London EC4A 4AB. Registered in England No 33774 Whilst Johnson Matthey aims to keep its network free from viruses you should note that we are unable to scan certain emails, particularly if any part is encrypted or password-protected, and accordingly you are strongly advised to check this email and any attachments for viruses. The company shall NOT ACCEPT any liability with regard to computer viruses transferred by way of email. Please note that your communication may be monitored in accordance with Johnson Matthey internal policy documentation. 2#