{"operation":"document","citation":"01-0086","title":"HMT Associates, L.L.C. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-06-01","effective_on":null,"summary":"01-0086 response to HMT Associates, L.L.C. concerning 173.312.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0086.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0086.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0086","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010086.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nUS. Department\nWashington.\n400 Seventh Street, S.W.\nD.C.\n20590\nSpecial Programs\nResearch and\nAdministration\nJUN\n1 2001\nMr. E. A. Altemos\nRef, No. 01-0086\nHMT Associates, L.L.C.\n1850 K Street, N.W.\nWashington, D.C. 20006-3500\nDear Mr. Altemos:\nThis responds to your March 20, 2001 letter concerning the packaging requirements for solid sodium\nchlorite, UN 1496, a Division 5.1 material under the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180) and the International Civil Aviation Organization's Technical Instructions for the Safe\nTransport of Dangerous Goods by Air (ICAO Technical Instructions). You state that the sodium\nchlorite is located inside a rigid plastic cartridge which is packaged in a 4G packaging. The inner 4G\npackaging is further packed in a IG fibre drum for shipment as a single package. Specifically, you\nrequest confirmation that a 1G fibre drum with a 4G inner packaging may be considered as a single\npackage for purposes of application of cargo aircraft package quantity limitations for domestic and\ninternational air transport.\nThe answer is yes. A 1G fibre drum that is an authorized single packaging for a hazardous material may\ncontain inner receptacles which are compatible with the lading as long as the inner receptacles would\nnot adversely impact the level of performance of the packaging. The packaging would remain marked\nas a single packaging. Therefore, for purposes of determining the package quantity limitation for air, a\n1G fiberboard drum with an inner 4G packaging, may be considered a single package.\nI hope this answers your inquiry.\nSincerely,\nEdward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards\n173. 212 (c)\n010086\n\n<<<PAGE 2>>>\n\nBoothe\n$173.212C)\nHMT ASSOCIATES, L.L.C.\nPackaging\n1850 K STREET, N.W.\nWASHINGTON, D.C. 20006-3500\nSUITE 200\nRet. No. 01-0086\nEA. ALTEMOS\n(202) 463-3511\nPATRICIA A. QUINN\nGORDON ROUSSEAU\nFACSIMILE (202) 463-3512\nWRITER'S DIRECT DIAL NUMBER\n(202) 463-3511, Ext. 11\nMarch 20, 2001\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards (DHM-10)\nResearch and Special Programs\nAdministration\nDepartment of Transportation\nWashington, D.C. 20590-0001\nDear Mr. Mazzullo:\nThis is to request confirmation that a particular method of packaging may be considered a\n\"single packaging\" under the provisions of the DOT Hazardous Materials Regulations (\"HMR\"; 49\nlimitations for domestic and international air transport. Of relevance in this connection, is an\nCFR Parts 171-180), including for purposes of application of cargo aircraft package quantity\ninterpretation previously issued by your office in the context of both the requirements of the HMR\nand the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe\nTransport of Dangerous Goods by Air (ICAO Technical Instructions), in which it is provided that\nan authorized single packaging containing a hazardous material in inner receptacles may remain\nmarked and, presumably, be transported as a single packaging.\nThe hazardous material concerned is a rigid plastic cartridge with a diameter of\napproximately three inches which contains solid sodium chlorite (UN 1496, Division 5.1, Packing\nGroup I). Each cartridge, which is an article designed to be used by insertion directly into a piece\nof equipment, contains approximately 2.8 pounds of sodium chlorite. This exceeds the maximum\ninner packaging quantity authorized for transport in a combinațion packaging by passenger aircraft\nunder both the HMR and ICAO Technical Instructions, and also exceeds the inner packaging\nquantity limit authorized for transport in a combination packaging by cargo-only aircraft under the\nICAO Technical Instructions. However, sodium chlorite is authorized to be transported by cargo-\n\n<<<PAGE 3>>>\n\n. \"\n...\nHMT ASSOCIATES, LL.C.\nMarch 20, 2001\nMr. Edward T. Mazzullo\nPage 2\nonly aircraft under both the HMR and the ICAO Technical Instructions in single packagings subject\nto a maximum net quantity per package of 25 kg.\nFor surface transport within the United States, several cartridges will be transported in UN\nstandard 4G single packagings, as authorized by § 173.212(c) of the HMR. For transport by cargo-\nonly aircraft, this container would be inserted in a UN standard 1G fibre drum, and held in place with\nappropriate securing and cushioning materials. The 1G fibre drum would be tested, marked and\ncertified as required for a single packaging used to transport sodium chlorite, and the fibreboard\ninner receptacle containing the cartridges would not affect the level of performance of the single\npackaging. Please confirm our understanding of the previously issued interpretation that, under these\ncircumstances, the 1G fibre drum may be considered a single packaging for purposes of transport\nunder the provisions of the HMR and the ICAO Technical Instructions.\nIn addition, please advise whether; under the circumstances described, you would consider\nit necessary to remove or obliterate any hazard labels, and/or packaging markings (e.g., proper\nshipping name, UN packaging certification markings, etc.) that appear on the 4G package before\nplacing that receptacle into the 1G fibre drum, in order that the fibre drum may be viewed as a\n\"package\" for purposes of transport under the provisions of the HMR and ICAO Technical\nInstructions.\nIlook forward to a reply at your earliest convenience. In the meantime, please do not hesitate\nto contact me if you have questions or require additional information regarding this matter.\nSincerely,\nE. A. Altemos\nEnclosure","truncated":false,"body_characters":5580}