Radian International — Hazardous Materials Safety Interpretation

Page 1113.328 of Transportation U.S. Department Washington SeS Washington, D.C. Special Programs Research and Administration ДРО : 26 1000 Mr. Andrew N. Romach Ref. No. 99-0056 Regulatory Compliance Manager Radian International Post Office Box 13000 Research Triangle Park, North Carolina 27709 Dear Mr. Romach: This clarification on the Hazardous Materials Regulations (HMR; 49 CFR is in response to your letter of March 4, 1999, reguesting Parts 171-180) as they pertain to the transportation of a Magnetic Resonance Imaging (MRI) Magnet machine by highway. You state that the MRI machine contains helium, refrigerated liquid as a refrigerant to keep the system at a low temperature during transit. Specifically, you ask whether the machine qualifies as a "process system" under the provisions in 49 CFR § 173.320 (b) (2). Based on the information you provided, the answer is yes. The machine qualifies as a process system and, as provided by § 173.320 (b) (2), is not subject to the requirements in 49 CER Process to tene Parts 171-180. Sincerely, Hothe z. mitchell Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 990056#

Page 2Betts RADIAN INTERNATIONAL 3173.320 A DAMES & MOORE GROUP COMPANY 99-0056 March 4, 1999 Mailing Address: Research Triangle Park, Post Office Box 13000 North Carolina 27709 MI. Ed Mazzullo, Director 1600 Perimeter Park Drive Physical/Shipping Address: Office of Hazardous Material Standards Research and Special Programs Administration Morrisville, North Carolina 27560 U.S. Department of Transportation 400 7th Street, SW 919 461 1100 Tel Washington, DC 20509-0001 919 461 1415 Fax FAX: (202) 366-3012 Dear Mr. Mazzullo: On behalf of GE Medical Systems Group, I am writing to you to request a written regulatory interpretation concerning the applicability of 49 CFR §173.320(b)(2) to the transport of Magnetic Resonance Imaging (MRI) Magnets by ground transportation. This provision reads as follows: (b)(2) The requirements of this subchapter do not apply to atmospheric gases and helium: When used in operation of a process system; such as a refrigeration system (pressure may exceed 25.3 psig). I have attached copy of a written interpretation from you addressed to Mr. Roy J. Miller, Hospital Support Service, Ltd., dated July 18, 1990. In this letter you stated that the "Magnetic Resonance Imaging Magnet $173.320(b)(2)." and a Balzer Cryogenic Refrigerator System" would qualify "as a process system, as provided by As described on page 2 of the original application submitted by Mr. Miller (also attached), the MRI contained in Hospital Support Service Ltd's mobile laboratory is manufactured by GE Medical Systems Group. GE Medical Systems Group currently manufactures this same type of magnet and frequently ships it magnet is similar to the magnet contained in the mobile unit. It contains a comparable amount of refrigerated by truck from our manufacturing facility directly to the hospital for immediate installation and use. Our liquid helium, which is functioning in the same manner as described in the original application to keep the both scenarios during transit, the refrigeration system containing the liquefied refrigerated helium that is magnet cold during shipment. In our particular case, the MRI is not operating during transit. However, in integral to the MRI does continue to maintain a very low temperature to ensure that the MRI will operate properly once it reaches its destination. Would the MRI manufactured by GE Medical Systems qualify as a "process system" for purposes of ground transportation and be able to take advantage of the exception provided in 49 CFR §173.320(b)(2)? If you have any questions concerning this request, please call me directly at (919) 461-1220. Regulatory Compliance Manager Radian International Engineering Services in North Carolina are performed through Radian Interational's wholty owned subsidiary, Radian Engineering Inc. Offices Worldwide#