{"operation":"document","citation":"00-0156","title":"Russell-Stanley — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-08-18","effective_on":null,"summary":"00-0156 response to Russell-Stanley concerning 173.227.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0156.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0156.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0156","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000156.pdf","body":"<<<PAGE 1>>>\n\n.S. Departmen\nf Transportatio\n400 Seventh St., S.W.\nWashington, D.C. 20590\nAUG 1 8 2000\nMr. Earl Lind\nRef. No. 00-0156\nDirector, Technology & Regulatory Affairs\nRussell-Stanley\n686 Route 202/206\nBridgewater, NJ 08807-1762\nDear Mr. Lind:\nThis is in response to your letter dated May 25, 2000, regarding the packaging requirements contained\nin 49 CFR 173.227, for materials poisonous by inhalation. Specifically, you ask if the closure\nconfiguration described in your letter satisfies the requirements of § 173.227(b)(2)(iii).\nYou described a plastic packaging having an opening that is internally threaded to accept a plug type\nscrew closure that has external threads designed to accept a screw cap closure. The screw cap closure\nis further held in place by the use of wire or plastic ties. The plug type screw closure is capable of\nmeeting an internal pressure of 250 kPa. The screw cap closure is capable of meeting an internal\npressure of 100 kPa. It is the opinion of this office that the closure configuration described in your\nletter satisfies the requirements of § 173.227(b)(2)(iii).\nI hope this satisfies your inquiry.\nSincerely,\nThoms. Allen\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n173.227\n000156\n\n<<<PAGE 2>>>\n\nS\nRussell-Stanley\nRUSSELL-STANLEY\n685 Route 202/206, Bridgewater, NJ 08807-1762\nTEL: (908) 203-9546 FAX: (908) 203-1944\ne-mail: elind @russell-stanley.com\nMay 25, 2000\ncale.\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n$ 173.227\nU.S. DOT/RSPA (DHM-10)\n400 7th Street S.W.\n00 - 0156\nWashington, D.C. 20590-0001\nTransmitted by e-mail\nRe: 49 CFR § 173.227 (b).\nDear Mr. Mazzullo,\nA. I am writing on behalf of Russell-Stanley Holdings, Inc. manufacturers of UN 1A1,\nUN1A2, UN 1H1, UN1H2 and UN 3H1 containers made in compliance with the\nperformance oriented packaging standards of 49 CFR Part 178 to request\ninterpretation regarding the provisions set forth in the section referenced above.\nSpecifically, I am requesting an opinion regarding the cap seal requirements outlined\nin 173.227(b)(2)(iii). As set forth in this section the primary closure must be secured\nwith a cap seal capable of withstanding and internal pressure of 100 kPa. This issue\nwas addressed in an interpretation dated August 8, 1994, ref. 7522 in which RSPA\nstated that if a hydrostatic pressure test is used to determine this capability a five\nminute test duration was adequate.\nNo specific design of a secondary seal is identified. In the industry the term \"cap\nseal\" is generally taken to mean a metal or combination plastic and metal seal which\nis applied over the primary closure, typically a plug, using a special tool. This type of\nseal is difficult to apply so as to be capable of meeting the 100kPa requirement\nThere is an interpretation dated April 22, 1994, kef.7534, in which RSPA said that a\nGHA1 composite packaging in which the inner receptacle having a screw type closure\nis capable of meeting the performance requirements of Packing Group I and the inner\nreceptacle is contained in a steel overpack with gasketed cover in turn capable of\nmeeting the 100 kPa internal pressure requirement meets the requirements of\n173.227(b)(2)(iii). This interpretation seems to permit alternate cap seal designs for\nachieving the desired purpose, namely, safety in transporting PIH materials.\nRussell-Stanley has proposed another means of achieving this objective that consists\nof a plastic UN having an opening that is internally threaded to accept plug type\nscrew closure and also having external threads designed to accept a screw cap\nclosure.\n\n<<<PAGE 3>>>\n\nThe screw cap closure is retained in place by the use of wire ties or plastic ties. A\ndrawing of this proposed closure system is shown below as Figure 1. Figures 2 & 3\nshow a composite with a closure system similar to the one proposed here. This was\nfound on an imported UN P.G. I composite.\nThe buttress plug is capable of meeting an internal pressure of at least 250 kPa and\nthe screw cap is the same as used on UN P.G. II drums having a 100 kPa pressure\nrating\nWe are asking if this closure system satisfies the provisions of 173.227(b)(2).\nB. In a separate issue with 173.227(b); the regulations authorize a UN 1H1\ncylindrical shaped drum for use in this service. As you may know there is a large\nnumber of UN 3H1 drums having a rated capacity of 60 liters or less manufactured\nfor chemical distribution. Russell-Stanley manufactures three different 20 liter 3H1\ndesigns, all with plug closures as an option. It has been our experience that the 3H1\ndesign has been able to achieve higher performance ratings than the cylindrical\nshape. Part of this is due to the shape. We currently manufacture a 3H1 design that\nhas been tested to the 350-kPa rating. The 1H1 designs primarily are rated to a lower\nrating, usually 100 - 150 kPa and have cap closures. The cap closure is not\nconducive to cap sealing because of its inherent design. Therefore, we believe the\n3H1 should also be a choice for shippers of small quantities in a single non-bulk\nwritten?\npackaging. Was the exclusion of this packaging an oversight when this section was\nI look forward to your reply and would greatly appreciate an early response as we\nhave customers looking forward to a positive reply.\nThank you in advance for your attention to this request.\nVery Truly Yours,\nCaulilinh\nEarl V. Lind\nDirector, Technology & Regulatory Affairs\ncc: T. Moses, M. Hunter, J. Bentz","truncated":false,"body_characters":5499}