{"operation":"document","citation":"00-0253","title":"Defense Logistics Agency — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-01-09","effective_on":null,"summary":"00-0253 response to Defense Logistics Agency concerning 173.27.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0253.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0253.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0253","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000253.pdf","body":"<<<PAGE 1>>>\n\ndministration\nJAN 2 4 2001\nMs. Linda McCarthy\nRef. No. 00-0253\n2001 Mission Drive\nDefense Logistics Agency\nNew Cumberland, PA 17070-5000\nDear Ms. McCarthy:\nThis is in response to your September 15, 2000 letter regarding\nthe general requirements in § 173.27 (c) for hazardous materials\noffered for transportation by aircraft under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically,\nyou state that thousands of your hazardous materials suppliers\nprovide no information on their hazardous material products'\nvapor pressures. You asked for information on how to convert a\nproduct's vapor pressure at 20 °C to its corresponding vapor\npressure at 50-55 °C or for us to provide a conversion chart for\nthis purpose.\nWe do not have this information available because of variations\nbest source for obtaining this information is from the product\nin concentrations\nand properties of hazardous materials.\nmanufacturers.\nobtain information\nAs you state, if you are unable to determine or\non the vapor pressures for the hazardous\nmaterial products, then\nthey must be packaged in accordance with\n§ 173.27 (c) (3).\nPlease contact us if we can be of further assistance.\nSincerely,\nHothe z. Michell\nHattie I. Mitchell, Chief\nOffice of Hazardous Materials Standards\nRegulatory Review and Reinvention\n173,27\n000253\n\n<<<PAGE 2>>>\n\n. 09/15/2000 12:54\n7177707143\nDDC T\nBettsin e2\nDEFENSE LOGISTICS AGENCY\nDEFENSE DISTRIBUTION CENTER\nHydrostatic.\nPressure\n2001 MISSION DRIVE\nNEW CUMBERLAND, PA 17070-5000\n20118.603\nIN REPLY\n00-0253\nREFERTO DDC-J3/J4-O\nMEMORANDUM FOR DEPARTMENT OF TRANSPORTATION\nATTN: MR. EDWARD MAZZULLO\nDIRECTOR OF HAZARDOUS MATERIALS STANDARDS\nU.S. DOT/RSPA (DHM10)\n400 7T STREET SOUTH WEST\nWASHINGTON, D.C. 20590-0001\nSUBJECT: Interpretation Request - Hydrostatic Pressure Test Level Requirements For\nCombination Packagings Of Hazardous Liquids\nThis office is responsible for testing of packagings for use by DoD components world-\npackagings for both solid and liquid hazardous materials. Our request for interpretation\nwide. We design and coordinate testing for a wide variety of single and combination\nconcerns the hydrostatic pressure test level requirements for PG I liquids in combination\npackagings being shipped by ait. We have read 49 CFR Paragraph 173.27 ® a number of\ntimes and understand the requirements of the paragraph to mean that we may test at the\ngreater of either 95 Kla or a calculation based upon the vapor pressure of the item being\nhipped at 55 degrees centigrade. The problem we are having is that we cannot determine\nhe temperature required by Paragraph 173.27 @. We were told by a number of our in\nve can convert the vapor pressure provided in the Material Safety Data Sheet (MSDS) tr\n›house chemists that this is impossible. Our advisor tells us \"There is no easy formula for\nwide variety of complex chemicals such as those found in hazardous materials\" Calling\ncompliance with the law, we must default to 250 kPa for all PG I items being shipped by\ndetermine which require testing to a level higher than 95kPa. To avoid being out of\nthan may be necessary and sometimes delays our shipments while our packers obtain air\nair. This forces us to use steel drums, spend more on our combination packaging designs\nmaterial from private industry. The packaging we purchased had an \"X* in the UN\neligible containers at the 250 kPa level. We attempted to purchase packagings for PG I\non the packaging. The packaging was also marked \"Tested for Air Shipment\". No where\nMarking and the test report indicated it was tested at 100 kPa. The 100 kPa was marked\non the packaging was it mentioned that the item you ship in the packaging could have a\nFederal Recycling Program a\nPrinted on Recycled Paper\n\n<<<PAGE 3>>>\n\non the packaging was it mentioned that the item you ship in the packaging could have a\nrequirement higher than 100 KPa and that the shipper should calculate the requirement. If\nthus packaging were use in the field, the packer would be led to believe that any PG I\nitem could be shipped in this packaging, and could be out of compliance. So, buying a\npackaging was not an answer.\nI have spoken to representatives at our test labs at LOGSA, Tobyhanna, and Naval\nUndersea Warfare Center, Keyport WA, as well as other DLA folks in the hazardous\nmaterials business and they all agree that the situation is not shipper friendly.\nExample: One of our MSDS sheets for a flammable liquid lists the following: \"Vapor\nPressure (HMHG/7OF): 180@20c\". Can you advise how to convert the vapor pressure at\n20c to the vapor pressure at 50-55c or provide a conversion chart that can be used for this\nprovide uniformity with the MSDS information, or can the paragraph be changed to\npurpose? If this is not possible, can the requirements in the 49 CFR be changed to\ntest pressure?\nreflect a requirement that will make it possible for the shipper to determine the required\nYour assistance is appreciated. POC for this matter is Ms. Linda MoCarthy, DSN:\n977-8238 (Commercial 717-770-8238) email: Imccarthy@ddc.dla.mil\nDirector of Distribution Operations","truncated":false,"body_characters":5097}