Defense Logistics Agency — Hazardous Materials Safety Interpretation

Page 1dministration JAN 2 4 2001 Ms. Linda McCarthy Ref. No. 00-0253 2001 Mission Drive Defense Logistics Agency New Cumberland, PA 17070-5000 Dear Ms. McCarthy: This is in response to your September 15, 2000 letter regarding the general requirements in § 173.27 (c) for hazardous materials offered for transportation by aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you state that thousands of your hazardous materials suppliers provide no information on their hazardous material products' vapor pressures. You asked for information on how to convert a product's vapor pressure at 20 °C to its corresponding vapor pressure at 50-55 °C or for us to provide a conversion chart for this purpose. We do not have this information available because of variations best source for obtaining this information is from the product in concentrations and properties of hazardous materials. manufacturers. obtain information As you state, if you are unable to determine or on the vapor pressures for the hazardous material products, then they must be packaged in accordance with § 173.27 (c) (3). Please contact us if we can be of further assistance. Sincerely, Hothe z. Michell Hattie I. Mitchell, Chief Office of Hazardous Materials Standards Regulatory Review and Reinvention 173,27 000253#

Page 2. 09/15/2000 12:54 7177707143 DDC T Bettsin e2 DEFENSE LOGISTICS AGENCY DEFENSE DISTRIBUTION CENTER Hydrostatic. Pressure 2001 MISSION DRIVE NEW CUMBERLAND, PA 17070-5000 20118.603 IN REPLY 00-0253 REFERTO DDC-J3/J4-O MEMORANDUM FOR DEPARTMENT OF TRANSPORTATION ATTN: MR. EDWARD MAZZULLO DIRECTOR OF HAZARDOUS MATERIALS STANDARDS U.S. DOT/RSPA (DHM10) 400 7T STREET SOUTH WEST WASHINGTON, D.C. 20590-0001 SUBJECT: Interpretation Request - Hydrostatic Pressure Test Level Requirements For Combination Packagings Of Hazardous Liquids This office is responsible for testing of packagings for use by DoD components world- packagings for both solid and liquid hazardous materials. Our request for interpretation wide. We design and coordinate testing for a wide variety of single and combination concerns the hydrostatic pressure test level requirements for PG I liquids in combination packagings being shipped by ait. We have read 49 CFR Paragraph 173.27 ® a number of times and understand the requirements of the paragraph to mean that we may test at the greater of either 95 Kla or a calculation based upon the vapor pressure of the item being hipped at 55 degrees centigrade. The problem we are having is that we cannot determine he temperature required by Paragraph 173.27 @. We were told by a number of our in ve can convert the vapor pressure provided in the Material Safety Data Sheet (MSDS) tr ›house chemists that this is impossible. Our advisor tells us "There is no easy formula for wide variety of complex chemicals such as those found in hazardous materials" Calling compliance with the law, we must default to 250 kPa for all PG I items being shipped by determine which require testing to a level higher than 95kPa. To avoid being out of than may be necessary and sometimes delays our shipments while our packers obtain air air. This forces us to use steel drums, spend more on our combination packaging designs material from private industry. The packaging we purchased had an "X* in the UN eligible containers at the 250 kPa level. We attempted to purchase packagings for PG I on the packaging. The packaging was also marked "Tested for Air Shipment". No where Marking and the test report indicated it was tested at 100 kPa. The 100 kPa was marked on the packaging was it mentioned that the item you ship in the packaging could have a Federal Recycling Program a Printed on Recycled Paper#

Page 3on the packaging was it mentioned that the item you ship in the packaging could have a requirement higher than 100 KPa and that the shipper should calculate the requirement. If thus packaging were use in the field, the packer would be led to believe that any PG I item could be shipped in this packaging, and could be out of compliance. So, buying a packaging was not an answer. I have spoken to representatives at our test labs at LOGSA, Tobyhanna, and Naval Undersea Warfare Center, Keyport WA, as well as other DLA folks in the hazardous materials business and they all agree that the situation is not shipper friendly. Example: One of our MSDS sheets for a flammable liquid lists the following: "Vapor Pressure (HMHG/7OF): 180@20c". Can you advise how to convert the vapor pressure at 20c to the vapor pressure at 50-55c or provide a conversion chart that can be used for this provide uniformity with the MSDS information, or can the paragraph be changed to purpose? If this is not possible, can the requirements in the 49 CFR be changed to test pressure? reflect a requirement that will make it possible for the shipper to determine the required Your assistance is appreciated. POC for this matter is Ms. Linda MoCarthy, DSN: 977-8238 (Commercial 717-770-8238) email: Imccarthy@ddc.dla.mil Director of Distribution Operations#