A2L Transportation Requirements

The US Department of Transportation (US-DOT) has the authority to regulate the transport of hazardous materials within the country. Refrigerants are classified as hazardous because they are a pressurized, liquefied gas. These regulations have been in effect for many years and include: 

 

• Using only DOT-approved cylinders (e.x. DOT-39 for disposables and DOT-4BA or 4BW for refillable cylinders) 
• Using the cardboard boxes for DOT-39 cylinders 
• Using valve caps for DOT-4BA cylinders,  
• Adhering to placarding requirements based on the total weight of refrigerants in a vehicle 

The regulations are strict, and violations can lead to significant fines. The specific regulations can be found on 49CFR parts 106, 107 and 171 to 180. 

Recently, the HVAC/R industry has started using, and transporting, A2L refrigerants which are slightly flammable. This prompted the DOT to review existing regulations. Key updates include: 

• Requiring a recloseable valve on DOT-39 cylinders used with A2L refrigerants 
• Mandating that A2L cylinders be transported so that the vapor phase is in communication with the safety relief valve 
• Practically, this means DOT-39 cylinders with rupture disks cannot be used for A2Ls, and all cylinders must be transported upright since the pressure relief valve is located at the top. 

These regulations are currently in effect, with one exception: companies can apply for a special permit from the DOT to be exempt from certain requirements. Arkema Inc. has received DOT-SP 21513 (issued on March 28, 2024, and valid for two years), allowing it to transport cylinders in a horizontal position. However, this permit only applies to that specific regulation; all other requirements must still be followed. 

It’s worth noting that customers of the permit holder can also utilize the special permit under specific conditions. This means that Arkema's SP allows our customers to transport Forane® refrigerant products, provided they do not modify the cylinders, carry a copy of the SP, and have received basic hazmat transportation training. 

Do you need more information about Arkema’s A2Ls? Check out our A2Ls info.