Bee Research Laboratory — Hazardous Materials Safety Interpretation

Page 1IS. Departmen if Transportation lashington, D. Research and pecial Program dministratio FEB - 5 2001 Mr. Jan Kochansky Research Chemist Reference No.: 00-0361 Bee Research Laboratory, Bldg. 476 10300 Baltimore Avenue Beltsville, MD 20705-2350 Dear Mr. Kochansky: This is in response to your December 18, 2000 letter requesting clarification on the procedures for testing compatibility and rate of permeation in plastic packagings. Specifically, you asked whether you may combine parts of the three test methods outlined in 49 CFR, Part 173, Appendix B. Section 173.24(e) requires that plastic packagings used for liquid hazardous materials be capable of withstanding without failure the procedure specified in Appendix B to Part 173. The procedure must be performed on all packagings used to transport liquid hazardous materials in Packing Group I. However, for Packing Group II and III materials, capability to withstand this test can be demonstrated through previous handling and transportation experience or design specification. Section 173.24(e)(3)(iii) permits alternative procedures to determine compatibility and permeation rate if they yield a level of safety equal to or greater than provided by paragraph (e)(3)(ii) and are approved by the Associate Administrator for Hazardous Materials Safety. The procedures for submitting an application for approval are prescribed in 49 CFR 107.705. I hope this satisfies your request. Please contact us if we can be of further assistance. Sincerely, Hothe z Mitchels Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 000361#

Page 2United States epartment ( Agricultural gricultur Research Beltsville Area Service Beltsville Agricultura Beltsville, Maryland Research Center 20705 Corbin §172:101 December 18, 2000 Att: Standards DHM-10 Associate Administrator for Hazardous Materials Safety Appendie B United States Department of Transportation Washington, DC 20590 Applicability Dear Sir: 00-0361 We are doing work to assist a licensee of a USDA patent on use of formic acid gel for control of Ve are currently testing screw-cap plastic jars, but have a question about the requirements of 4 FR 173 Appendix B for determination of compatibility and permeation rate of plasti packagings. Would it be permissible to combine parts of the three test methods? Specifically, could the first and last 24 hours (container inverted) of the test be run at room temperature with the specified period upright at one of the specified higher temperatures (50 or 60°C)? For example, 24 hours inverted at 25°C, 14 days upright at 60°C, then 24 hours inverted at 25°. The gel has a tendency to leak out of the inverted container at 60°C but does not do so at 25°C. The shorten the total duration of the test in order to expedite container selection and testing. product will be shipped, stored, and used at nominal room temperature-we are only using 60°C to If this modification is not permissible, please advise on the procedure for requesting an exemption. Sincerely, Kookaway JAN KOCHANSKY Research Chemist 10300 Baltimore Ave. Bee Research Laboratory, Bldg. 476 Beltsville, MD 20705-2350 301 504 8668 301 504 8736 (fax) kochansj@ba.ars.usda.gov#