Interpretation Response #12-0231
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
March 11, 2013
Mr. Damien Belot
SIEMENS Industry, Inc.
CPS FS Research Unit
8 Fernwood Road
Florham Park, NJ 07932
Reference No. 12-0231
Dear Mr. Belot:
This is in response to your October 11, 2012 e-mail and subsequent telephone conversation with a member of my staff requesting clarification applicable to a fire extinguisher system under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter, you describe a fire extinguisher system which uses cylinders containing inert gases such as Argon, Nitrogen, and Inergen+. This fire extinguishing system is installed where critical devices or precious goods must not be damaged by fire. The fire extinguishing system contains non-Department of Transportation (DOT) specification cylinders with pressures of up to 3000 psi that are equipped with a valve on which threaded bosses can receive gauges. When the boss is not used, it is covered with a protection cap. You ask what are the transportation requirements under the HMR when shipping the described fire extinguishing systems as a whole. You also ask whether the cylinders in the fire extinguisher systems would be required to have a pressure gauge installed.
Based on the information you provided, the system you describe cannot be transported in conformance with the HMR. It is the opinion of this Office that the cylinders in the fire suppression system you describe are required to be specification cylinders in accordance with requirements for Class 2 non-flammable gas. Because the cylinders are non-specification cylinders, your company would need to apply for a special permit under § 107.105 of the HMR.
I hope this satisfies your request.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division