{"operation":"document","citation":"02-0058","title":"Troxler Electronic Laboratories, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-03-26","effective_on":null,"summary":"02-0058 response to Troxler Electronic Laboratories, Inc. concerning 173.475.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0058.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0058.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0058","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020058.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh St., S.W.\nWashington, D.C. 20590\npecial Program:\nresearch and\nAdministration\nMAR 2 6 2002\nMr. Stephen A. Browne\nCorporate Radiation Safety Officer\nRef. No. 02-0058\nTroxler Electronic Laboratories, Inc.\nBox 12057\nResearch Triangle Park, NC 27709\nDear Mr. Browne:\nThis is in response to your November 13, 2001 letter concerning radioactive packaging requirements\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We apologize for the\ndelay in responding to your letter due to mail delivery problems many Federal agencies have been\nexperiencing because of screening and decontamination precautions.\nSpecifically, you request clarification on whether cracks which penetrate the full depth of the wall (either\nradioactive material would be in violation of the regulations. You cite § 173.475(b) which states that\ninner or outer) of a shipping case designed to transport scientific gauges containing special form\npackaging required to transport these gauges must be \".. in unimpaired physical condition, except for\nsuperficial marks.\" You state that these cracks do not meet the requirements in this section.\nYour opinion is correct. The cracks in the shipping case described in your letter compromise the\nphysical integrity of the packaging, increasing the chance that the packaging could fail during incidents\nnormal to transportation. Scratches and scuffs are examples of surface marks that would not\ncompromise the physical integrity of the packaging and would be considered \"superficial marks.\"\nI hope this satisfies your request.\nSincerely,\nDeln\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\nANNALI HI\n173.475(6)\n020058\n\n<<<PAGE 2>>>\n\nJohnsen\nTROXLER\n8173. 475(b)\nNovember 13, 2001\nRAM\nMr. Edward T. Mazzulo\n!!! i\nDirector, Office of Hazardous Materials Standards\n1:10 -71\n02-0058\n400 7th Street S.W.\nU.S. DOT/RSPA (DHM 10).. ^\nWashington, D.C. 20590000... 1C\nDear Mr. Mazzullo:\nI am writing to request clarification on the quality control requirements in 49 CFR 173.475(b) for packages\ncontaining splaar forma quai. Troxier manufactures and repairs portable moisture density gauges\nType A package requirements The shipping cases are injection-molded plastic, double-walled construction\nweas. Thu gaugts at snipped in reusable shipping cases that Tett\nwith an air void between the inner and outer walls (see enclosure 1 for photo of a typical shipping case and\ngauge).\nCustomers periodically ship gauges to Troxler for calibration and repair. Before returning a gauge to a\n10%) develop cracks in the inner wall where the weight of the equipment rests most heavily (see enclosure\ncustomer, the shipping casc is inspected in accordance with §173.475: Over time, some shipping cases (5-\n2 for photo of a typical crack). Troxier considers a shipping case with any cracks to be defective,\nregardless of whether the crack is on the inner or outer wall, since the body of the case is a single, molded\nreturn their gauge.\npicce. In these situations, we advise the customer that the shipping case must be replaced before we can\nSome customers have challenged the need to replace the shipping case, arguing that the package is\nmaterial during shipping.\nunimpaired because, based on experience; the cracks do not affect the containment of the radioactive\nWe agrec that loss of radioactive material containment is unlikely, however, according to 173.475(b), the\ncracks which penctrate the full depth of the wall (either inner or outer) are more than superficial marks,\npackage must be in unimpaired physical condition, except for superficial marks. Our interpretation is that\n-thus the package does not meet the standard.\nWe want to comply with DOT requirements, but we do not want to force customers to purchase new\nquality control inspection criteria in $173.475(b) is correct or not in this situation.\nshipping cases unnecessarily. Therefore, we would like clarification on whether our interpretation of the\nSincerely,\nStephen A. Browne\nCorporate Radiation Safety Officer\nEnclosures (2)\nTroxler Electronic Laboratories, Inc\nBox 12057 + 3008 Cornwallis Road • Research Triangle Park, North Carolina 27709\nTel: (919) 549-8661 • Fax: (919) 485-2250 + e-mail: troxrso@troxlerlabs.com","truncated":false,"body_characters":4259}