DOT Provides Interpretation for CO2 Extinguishers
Wednesday, January 20, 2016
Posted by: Tamara Matthews
Last year a NAFED member was inspected by the US Department of Transportation and was given probable violations for involving a carbon dioxide fire extinguisher. The probable violations included that the carbon dioxide fire extinguisher was labeled and listed on the shipping paper as Carbon Dioxide UN 1013 and not labeled as a Fire Extinguisher UN 1044.
At the request of the NAFED member we reached out to the DOT and explained that we had been told previously that a CO2 fire extinguisher had to be shipped as Carbon Dioxide UN 1013 and not as a fire extinguisher. This was stated as such in CFR 49 Section 173.309 (a) (3) which states "(3) A fire extinguisher may not contain more than 30% carbon dioxide by volume or any other corrosive extinguishing agent."
It was suggested that we ask for a written interpretation on this matter, and we did so in June of 2015. We have recently received the formal interpretation from the DOT that confirms that for transportation purposes a CO2 fire extinguisher shall not be considered a fire extinguisher UN 1044 but is Carbon Dioxide UN 1013 and must be labeled and entered on the shipping paper that way.