HMT Associates, L.L.C. — Hazardous Materials Safety Interpretation

Page 1of Transportation US. Department Washington. 400 Seventh Street, S.W. D.C. 20590 Special Programs Research and Administration JUN 1 2001 Mr. E. A. Altemos Ref, No. 01-0086 HMT Associates, L.L.C. 1850 K Street, N.W. Washington, D.C. 20006-3500 Dear Mr. Altemos: This responds to your March 20, 2001 letter concerning the packaging requirements for solid sodium chlorite, UN 1496, a Division 5.1 material under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions). You state that the sodium chlorite is located inside a rigid plastic cartridge which is packaged in a 4G packaging. The inner 4G packaging is further packed in a IG fibre drum for shipment as a single package. Specifically, you request confirmation that a 1G fibre drum with a 4G inner packaging may be considered as a single package for purposes of application of cargo aircraft package quantity limitations for domestic and international air transport. The answer is yes. A 1G fibre drum that is an authorized single packaging for a hazardous material may contain inner receptacles which are compatible with the lading as long as the inner receptacles would not adversely impact the level of performance of the packaging. The packaging would remain marked as a single packaging. Therefore, for purposes of determining the package quantity limitation for air, a 1G fiberboard drum with an inner 4G packaging, may be considered a single package. I hope this answers your inquiry. Sincerely, Edward T. Mazzullo Director, Office of Hazardous Materials Standards 173. 212 (c) 010086#

Page 2Boothe $173.212C) HMT ASSOCIATES, L.L.C. Packaging 1850 K STREET, N.W. WASHINGTON, D.C. 20006-3500 SUITE 200 Ret. No. 01-0086 EA. ALTEMOS (202) 463-3511 PATRICIA A. QUINN GORDON ROUSSEAU FACSIMILE (202) 463-3512 WRITER'S DIRECT DIAL NUMBER (202) 463-3511, Ext. 11 March 20, 2001 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards (DHM-10) Research and Special Programs Administration Department of Transportation Washington, D.C. 20590-0001 Dear Mr. Mazzullo: This is to request confirmation that a particular method of packaging may be considered a "single packaging" under the provisions of the DOT Hazardous Materials Regulations ("HMR"; 49 limitations for domestic and international air transport. Of relevance in this connection, is an CFR Parts 171-180), including for purposes of application of cargo aircraft package quantity interpretation previously issued by your office in the context of both the requirements of the HMR and the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), in which it is provided that an authorized single packaging containing a hazardous material in inner receptacles may remain marked and, presumably, be transported as a single packaging. The hazardous material concerned is a rigid plastic cartridge with a diameter of approximately three inches which contains solid sodium chlorite (UN 1496, Division 5.1, Packing Group I). Each cartridge, which is an article designed to be used by insertion directly into a piece of equipment, contains approximately 2.8 pounds of sodium chlorite. This exceeds the maximum inner packaging quantity authorized for transport in a combinațion packaging by passenger aircraft under both the HMR and ICAO Technical Instructions, and also exceeds the inner packaging quantity limit authorized for transport in a combination packaging by cargo-only aircraft under the ICAO Technical Instructions. However, sodium chlorite is authorized to be transported by cargo-#

Page 3. " ... HMT ASSOCIATES, LL.C. March 20, 2001 Mr. Edward T. Mazzullo Page 2 only aircraft under both the HMR and the ICAO Technical Instructions in single packagings subject to a maximum net quantity per package of 25 kg. For surface transport within the United States, several cartridges will be transported in UN standard 4G single packagings, as authorized by § 173.212(c) of the HMR. For transport by cargo- only aircraft, this container would be inserted in a UN standard 1G fibre drum, and held in place with appropriate securing and cushioning materials. The 1G fibre drum would be tested, marked and certified as required for a single packaging used to transport sodium chlorite, and the fibreboard inner receptacle containing the cartridges would not affect the level of performance of the single packaging. Please confirm our understanding of the previously issued interpretation that, under these circumstances, the 1G fibre drum may be considered a single packaging for purposes of transport under the provisions of the HMR and the ICAO Technical Instructions. In addition, please advise whether; under the circumstances described, you would consider it necessary to remove or obliterate any hazard labels, and/or packaging markings (e.g., proper shipping name, UN packaging certification markings, etc.) that appear on the 4G package before placing that receptacle into the 1G fibre drum, in order that the fibre drum may be viewed as a "package" for purposes of transport under the provisions of the HMR and ICAO Technical Instructions. Ilook forward to a reply at your earliest convenience. In the meantime, please do not hesitate to contact me if you have questions or require additional information regarding this matter. Sincerely, E. A. Altemos Enclosure#