High Precision Gas — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration January 6, 2022 1200 New Jersey Avenue, SE Washington, DC 20590 Mr. Justin Wai High Precision Gas 10770 Painter Avenue Santa Fe Springs, CA 90670 Reference No. 21-0090 Dear Mr. Wai: This letter is in response to your September 8, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinder markings. Specifically, you ask whether a cylinder may have a marking with the proper shipping name of “UN1075, Petroleum gases, liquefied, 2.1,” as well as a secondary marking of “Butane.” In accordance with 49 CFR 172.301(a)(1), each person who offers a hazardous material for transportation in a non-bulk packaging must mark the package with the proper shipping name and identification number for the material contained within, as shown in the § 172.101 Hazardous Materials Table. However, special provision 19 permits use of the identification number “UN1075” in place of “UN1011” for butane in domestic transportation only. Based on the information provided in your email, your hazardous material may be described and marked as either “UN1075, Petroleum gases, liquefied, 2.1,” or “UN1075, Butane, 2.1.” The identification number used must be consistent on package markings, shipping papers, and emergency response information. While the HMR do not prohibit the inclusion of “Butane” as a secondary marking in addition to the proper shipping name of either “UN1075, Petroleum gases, liquefied, 2.1,” or “UN1075, Butane, 2.1,” this may cause confusion in transportation and result in the frustration of your shipment. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Ballengee 21-0090 From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: Interpretation on LPG Cylinder labeling Date: Wednesday, September 8, 2021 4:38:29 PM Attachments: image.png Below is a request for letter of interpretation. Thanks, Jonathon, HMIC From: Justin@HPG <justin@highprecisiongas.com> Sent: Wednesday, September 8, 2021 3:57 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Interpretation on LPG Cylinder labeling CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Hi, Is it okay to have two proper shipping names on the same LPG cylinder like in the picture below? For example, having 'Liquefied Petroleum Gas' on the main label with a separate label that has additional property information on it such as 'Butane'. Respectfully, JUSTIN WAI (866) 868-6525 ext.704 | Justin@HighPrecisionGas.com 10770 Painter Ave, Santa Fe Springs, CA 90670 This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error, please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not#

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