Guidanceguidance
99-0318
Printronix — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research99-0318
Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research and Special Programs Administration DEC 1 7 1999 Ms. Kathryn Parham Ref. No. 99-0318 Customer Administration Printronix 14600 Myford Rd Irvine, CA 92623-9559 Dear Ms. Parham: This is in response to your letter dated November 19, 1999, Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to requesting clarification regarding the applicability of the the transportation of accumulators. Specifically, you ask if the HMR apply to replacement accumulators not assembled in machinery and accumulators transported in assembled machinery. As provided by § 173.306 (f) (1), accumulators which are installed in assembled machinery and constructed with a burst pressure of at least five times their charged pressure at 70°F are not subject to the HMR. Accumulators, as described in $ 173.306 (f), not in assembled machinery are subject to the HMR. However, accumulators intended to function as shock absorbers, struts, gas spring, pneumatic springs or other impact or energy-absorbing devices are not subject to the HMR provided they meet the criteria specified in S : 173.306 (f) (4) . I hope this satisfies your request. Sincerely, Transportation Regulations Specialists Gale Office of Hazardous Materials Standards 990318 173.306#
Page 2PRINTRONIX® ISO 9000 Registered Worldwide Irvine, California 92623-9559 14600 Myford Road, P.O. Box 19559 sending Telephone (714) 368-2300 Mollie Fax (714) 368-2358 http://www.printronix.com Apprived "/16l99. or • 11/16/99 Department of Transportation Al Roberts 30202364-4470 Attention DHM-31 Associate Administrator for Hazardous Materials Safety, Del Thingle: research and Specials Programs Administration Linda Booth. United States of America Department of Transportation Darg. Sm.l (2023664436 Washington, D.C. 20590 ( 202) 3406-7100 REF: D.O.T. Shipping Regulations Standards Tech- 202342-4545-Charle Hockings i have attached a copy of the current Material Safety Data sheet for shipment of Gas Spring Assy's via air to several international locations. Please review the attached documentation and advise / confirm if this product is a dangerous good when: * 1. Shipped individually as just gas springs to be used for replacement parts. 2. Shipped when installed on a Computer Printer Unit, generally two gas springs per printer. Please provide a regulatory reference and any exemptions that may be used. Del Billap If you require additional information, 1 may be reached at (714) 368-2956. Please forward all information to: Standards- • = . Printronix Inc. J 14600 Myford Road 346-8553 Irvine, CA 92606 Attr: Kathryn Parham (207) Thank you advance for your time and consideration. Kathryn Parhar Printronix Inc. Export Compliance#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.