Guidanceguidance
99-0297
Neiman Marcus Direct — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research99-0297
Page 1US. Department 400 Seventh Street, S.W. of Transportation Washington. D.C. 20590 Research and Special Programs Administration NOV 19 1999 Mr. Frank Ramirez Ref. No. 99-0297 Neiman Marcus Direct 111 Customer Way Irving, TX 75039 Dear Mr. Ramirez: This is in response to your letter dated October 28, 1999, regarding inner container pressure requirements for limited quantities of compressed gasses under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if an inner container meeting the requirements under $ 173.306 (a) (1) may be charged to a pressure exceeding 180 psig at 130°F. The answer is yes. Inner containers shipped under the provisions of $ 173.306(a) (1) have no pressure limits. I hope this satisfies your request. Sincerely, Deman Blings Office of Hazardous Materials Standards Chief, Standards Development 173.306% 990297#
Page 2DIRECTOR OF DISTRIBUTION FRANK RAMIREZ 972-401-6694 (OFFICE) 972-401-6764 (FAX) Neiman Marcus Direct 214992-5681 (PAGER) BAH 173:300 Facsimile 99-0297 To: Edward Mazzullo Director OHMS US DOT / RSPA (DHM-10) 400 7th Street S.W. Washington, D.C. 20590 •. From: FRANK RAMIREZ @Fax: 202-365-3012 Date: 10/28/99 Consumer Commodity Pages: 1, including this Mr. Mazzullo, I am reviewing the mailability of a product described as a screwless wine opener and refills class/division is 2.2. ID number is UN3159. It is a nonflammable gas. The product qualifies as (15 grams) which contain the chemical 1,1,1,2 Tetraflouroethane or refrigerant gas R134A. The a Consumer Commodity ORM-D. One question I have is in the interpretation of CFR49 173.306 (a) (3) (ii), which states "pressure in the container must not exceed 180 psig at 130 degrees F." The product has a psig of 198.7 at 130 degrees F. I talked to Arthur at the DOT 800 number. He clarified the fact that in paragraph (h) of ; section 173.306 that the product in limited quantity conforms with (a) (1) allowing (a) (3) (ii) to be a non-issue. Mr. Mazzullo, I would appreciate a confirmation letter from your office of this fact for my, files. Please fax it to my attention at 972-401•6764. If you require any additional information, please call me at 972.401.6694. Per conve a/ Arther Polloch, Sincerely, the can tiner is less the a fled Ot and is ships and 173.60l.#
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