{"operation":"document","citation":"99-0056","title":"Radian International — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-04-26","effective_on":null,"summary":"99-0056 response to Radian International concerning 173.320.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0056.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0056.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0056","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990056.pdf","body":"<<<PAGE 1>>>\n\n113.328\nof Transportation\nU.S. Department\nWashington SeS\nWashington, D.C.\nSpecial Programs\nResearch and\nAdministration\nДРО\n: 26 1000\nMr. Andrew N. Romach\nRef. No. 99-0056\nRegulatory Compliance Manager\nRadian International\nPost Office Box 13000\nResearch Triangle Park, North Carolina 27709\nDear Mr. Romach:\nThis\nclarification on the Hazardous Materials Regulations (HMR; 49 CFR\nis in response to your letter of March 4, 1999, reguesting\nParts 171-180) as they pertain to the transportation of a\nMagnetic Resonance Imaging (MRI) Magnet machine by highway. You\nstate that the MRI machine contains helium, refrigerated liquid\nas a refrigerant to keep the system at a low temperature during\ntransit.\nSpecifically, you ask whether the machine qualifies as\na \"process system\" under the provisions in 49 CFR\n§ 173.320 (b) (2).\nBased on the information you provided, the answer is yes. The\nmachine qualifies as a process system and, as provided by\n§ 173.320 (b) (2), is not subject to the requirements in 49 CER\nProcess to tene\nParts 171-180.\nSincerely,\nHothe z. mitchell\nHattie I. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n990056\n\n<<<PAGE 2>>>\n\nBetts\nRADIAN INTERNATIONAL\n3173.320\nA DAMES & MOORE GROUP COMPANY\n99-0056\nMarch 4, 1999\nMailing Address:\nResearch Triangle Park,\nPost Office Box 13000\nNorth Carolina 27709\nMI. Ed Mazzullo, Director\n1600 Perimeter Park Drive\nPhysical/Shipping Address:\nOffice of Hazardous Material Standards\nResearch and Special Programs Administration\nMorrisville, North Carolina 27560\nU.S. Department of Transportation\n400 7th Street, SW\n919 461 1100 Tel\nWashington, DC 20509-0001\n919 461 1415 Fax\nFAX: (202) 366-3012\nDear Mr. Mazzullo:\nOn behalf of GE Medical Systems Group, I am writing to you to request a written regulatory interpretation\nconcerning the applicability of 49 CFR §173.320(b)(2) to the transport of Magnetic Resonance Imaging\n(MRI) Magnets by ground transportation. This provision reads as follows:\n(b)(2) The requirements of this subchapter do not apply to atmospheric gases and helium: When used in\noperation of a process system; such as a refrigeration system (pressure may exceed 25.3 psig).\nI have attached copy of a written interpretation from you addressed to Mr. Roy J. Miller, Hospital Support\nService, Ltd., dated July 18, 1990. In this letter you stated that the \"Magnetic Resonance Imaging Magnet\n$173.320(b)(2).\"\nand a Balzer Cryogenic Refrigerator System\" would qualify \"as a process system, as provided by\nAs described on page 2 of the original application submitted by Mr. Miller (also attached), the MRI\ncontained in Hospital Support Service Ltd's mobile laboratory is manufactured by GE Medical Systems\nGroup. GE Medical Systems Group currently manufactures this same type of magnet and frequently ships it\nmagnet is similar to the magnet contained in the mobile unit. It contains a comparable amount of refrigerated\nby truck from our manufacturing facility directly to the hospital for immediate installation and use. Our\nliquid helium, which is functioning in the same manner as described in the original application to keep the\nboth scenarios during transit, the refrigeration system containing the liquefied refrigerated helium that is\nmagnet cold during shipment. In our particular case, the MRI is not operating during transit. However, in\nintegral to the MRI does continue to maintain a very low temperature to ensure that the MRI will operate\nproperly once it reaches its destination.\nWould the MRI manufactured by GE Medical Systems qualify as a \"process system\" for purposes of ground\ntransportation and be able to take advantage of the exception provided in 49 CFR §173.320(b)(2)?\nIf you have any questions concerning this request, please call me directly at (919) 461-1220.\nRegulatory Compliance Manager\nRadian International\nEngineering Services in North Carolina are performed through Radian Interational's wholty owned subsidiary, Radian Engineering Inc.\nOffices Worldwide","truncated":false,"body_characters":4005}