PHMSA Response Letter

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January 11, 2016

Mr. Brad Storm
Hazardous Materials Specialist
John Deere TCAO
3500 E Donald St
Waterloo, IA 50703
Bldg 6011 ESB-2 373

Ref. No. 15-0179

Dear Mr. Storm:

This responds to your August 24, 2015 request for clarification pertaining to accumulators under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether an accumulator in a "hydraulic system used to maintain constant pressure, build pressure gradually and store energy" is eligible for the exception in § 173.306(f)(4) provided the accumulators otherwise meet the requirements in § 173.306(f)(4)(i) to (iv) of the HMR.

The requirement in § 173.306(f)(4) applies to accumulators intended to function as shock absorbers, struts, gas springs, pneumatic springs or other impact or energy-absorbing devices. Based on the information contained in your letter, the accumulators are not intended to function in any of these capacities and would therefore not be eligible for this exception. However, it should be noted that other exceptions for accumulators are provided in § 173.306(f)(1), (2), (3), and (5).

I hope this satisfies your request.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.306(f)(4), 173.306(f)(4)(i) to (iv), 173.306(f)(1), (2), (3), and (5)