Classification of Aegis Water Cooler
Pipeline and Hazardous Materials Safety Administration · Jun 4, 1997 · Reference No. 97-0187
Interprets: 49 CFR § 173.174
Reggie’s quick take
Someone asked whether a large Aegis Water Cooler holding less than 12.8 ounces of a class 3 flammable liquid can be shipped as "Refrigerating machine, NA1993." PHMSA says yes. The cooler can be described that way and shipped under § 173.174, which allows a refrigerating machine with 7 kg (15 pounds) or less of flammable liquid for its operation, in a strong, tight receptacle.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter of May 2, 1997, requesting clarification of the requirements for shipping a large Aegis Water Cooler under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -180). Specifically, you asked whether a large Aegis Water Cooler containing less than 12.8 oz of a class 3(flammable liquid) maybe described as "Refrigerating machine, NA1993" under § 173.174.
The answer is yes. This item can be described as a "Refrigerating machine" and shipped in accordance with 49 CFR 173.174. That section allows shipment of a refrigerating machine containing 7 kg (15 pounds) or less of a flammable liquid for its operation in a strong, tight receptacle.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.