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NAFED eAlert for May 15, 2012.

Transporting Fire Extinguishers:
a DOT Clarification

The US DOT has recently issued two interpretations that directly affect the transportation of fire extinguishers (see links below). Before you read the interpretations you should first review the DOT definition of fire extinguishers in CFR 49 Section 173.309.

§173.309 Fire extinguishers.
(a) Fire extinguishers charged with a limited quantity of compressed gas to not more than 1660 kPa (241 psig) at 21° C (70° F) are excepted from labeling (except when offered for transportation by air) and the specification packaging requirements of this subchapter when shipped under the following conditions. In addition, shipments are not subject to subpart F of part 172 of this subchapter, to part 174 of this subchapter except §174.24 or to part 177 of this subchapter except §177.817.
(1) Each fire extinguisher must have contents which are nonflammable, non-poisonous, and noncorrosive as defined under this subchapter.
(2) Each fire extinguisher must be shipped as an inner packaging.
(3) Nonspecification cylinders are authorized subject to the following conditions:…
 
The key points of the DOT interpretations included with this email are:
  1. When required, fire extinguishers are to be marked and labeled as Fire Extinguisher, UN 1044, and should not be marked or labeled as Nitrogen, Compressed.
  2. Shipping paper entries must identify the extinguishers as UN1044, Fire Extinguisher, 2.2.
  3. Fire extinguishers that are shipped as an inner packaging (in a box) meet the requirements for limited quantity and therefore the weight of those extinguishers does not apply to placarding considerations. However, you must also change the shipping paper entry to read: UN1044, Fire Extinguishers Limited Quantity, 2.2. You are allowed to abbreviate “Limited Quantity” to “Ltd Qty” (see note).
  4. Shipping papers are required for fire extinguishers that are transported as Limited Quantity regardless of the exception allowed in CFR 49 Section 177.200 (b)(3).
  5. All fire extinguishers that are not transported as inner packaging may be transported as “Materials of Trade” as defined in CFR 49 Section 171.8 and conforming to Section 173.6. These fire extinguishers are those that are not being transported for commerce but are used “in direct support of a principal business that is other than the transportation by motor vehicle.”
  6. Other fire extinguishers that are not transported as inner packaging must be properly secured and marked as Fire Extinguisher, UN1044, and labeled with the Division 2.2 label. Note: A change last year in the regulations requires that the packaging containing a Limited Quantity Material must be marked with both the proper shipping name and the UN identification number. This means that any box, crate, etc., that is used to contain fire extinguishers needs to be marked Fire Extinguisher, UN1044.
The US DOT is looking at the transportation of fire extinguishers so don’t be surprised if during a DOT facility inspection they ask to review your shipping methods and paperwork. NAFED is monitoring the DOT’s activities and is working with other industry members to grasp what these interpretations mean to the individuals that transport and service fire extinguishers. We expect that we will have most of our questions and concerns addressed with the DOT later this year.

Interpretation Letter #1

Interpretation Letter #2
Our executive directors, Danny Harris and Norb Makowka, received certificates of proclamation from the mayor of New Orleans during our annual meeting this year. Congrats to Danny and Norb!
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