Boeing - Long Beach Division — Hazardous Materials Safety Interpretation

Page 1• 5. Departmer Transportatic Washington, S 20590 special Programs Administration ОСт 2 8 2002 Mr. Scott W. Chapman Boeing - Long Beach Division Ref. No. 02-0224 19270 Western Avenue Torrance, CA 90501 Dear Mr. Chapman: This is in response to your August 26, 2002 letter concerning package testing requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you requested clarification concerning the relative humidity requirements for testing paper and fiberboard packagings in § 178.602. You state that while the HMR requires margin of error of +2% in determining relative humidity, the machine you use has a margin of error of 15%. Section 178.602 (d) requires the packaging to be maintained at least 24 hours prior to testing in an to a 15% deviation (45% or 55% relative humidity) for short term fluctuations in this minimum 24-hour environment with 50% relative humidity, plus or minus 2%. In addition, the requirements allow for up period. The average relative humidity would be calculated for at least 24 hours before the test, and would allow for ‡5% deviation spikes, but the average relative humidity must remain between 48% and 52%. You equipment will need to be accurate enough to ensure that the pre-test environment falls within these specifications. Your equipment and subsequent data display may be of any number of technologies or styles, but it is the responsibility of the equipment owner to be able to read and verify that the packaging was in an environment that meets these criteria for at least 24 hours prior to testing. If you feel this criteria is too restrictive, then you may petition RSPA for a change to the regulations under the process outlined in § 106.31 of the 49 CFR. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 178.602 020224#

Page 2• AUG-26-2002 11:33 BOEING 310 972 7303 P.01 @BOEING: Johnsen A Division of McDonnell Douglas Corporatior Long Beach Division, A Wholly Owned Subsidiary of The Boeing Company $178.602 Torrance, California 90501 19270 Western Avenue PACKAGING ENGINEERING lesting August 26, 2002 02-0924 To Edward T. Mazzullo: I was hoping you could give me a response in writing that our humidity tolerances maintained by our test requirement for IATA and CFR49 below. equipment are acceptable as recorded for our fibreboard sample conditioning. See excerpted JATY Dangerous Goods Ragulations 80 long as thay. ara piaded so hat the test resulls are not invalldated. 322 l te dr faste for liquide, when another (specific gravity) and viscosity should be similar to 1h03e.of subslance is used, it must be of similar relative density the substance being transported. Wasor may also be usad 6.9.3.4. for the lauld drop test under the conditions set lorth in 83.27:: Pip tomboard sk her dondl Đho he/was must all within chaselims, Shot. on inha not capital relate §178.602 Preparation of packagings and packnges for resting sting and resis must be carriod our in the samt manner as if propared, for bansporatión, inaluding inner packaginga ) Excopi as utharwise provided in this subehapter, each prokaging and paclonge maar da oldeed in preparation f tho ceso of combinailon packuginge. for chamical compalbility resting or wirre this would invalidate the results of the tesis. be of the same or higher specific gravity as the matotial to be carried, and its other physical propertiós Cerain, size, viscos. (e) If tbe Distarial to be transported is replaced for test ptuposes by a non- hazardous material, tha material used must ity) which might influence be results of tho required tests must curiospond as clodely ds positile to rhose of the hazard. ;178.603(e) of this subpart. It is permissible to use ndditives. auch as bags of lead shot, to achieye the roquiaite total park. us tasterial to be transported. Wards may sisu bo aeed for the liquid drop cas under the conditions specified in ago mass, to long as they are placed so that the test results are not affected. sphere invintained— (d) Paper or fiberboard packagings must be conditioned for at least 34 houra immediately prior to besting in an ntmo. are tastes tales and measurement limicalion may cauda individual incuxurements (1) du SD pescent = 2 percent rolntire humidiry, and at a lemperaturo of 23° C= 2° C (73° Ft 4° F), Average values to vary by up o= 5 paicent relative humidity will signifieant impoirment of bost reproduciblity: (81° Fg4° 1). Averace valies shuald tall withie these limits, Short-torm Doctuations and raessurement limitations m* 2) At 65 percent + 2 pezernt colative humidiry, and nt a lemberrue of 20º C* 20C 9[=40M*C+? cause individual measureinenes to Vary by up lo = 5 percent relative humidity without significont impair ment of test (3) For resting at periodic intervals only G.e., arher thon initiat design qualification resting), at arbient conditions.#

Page 3„AUG-26-2002 11:33 BOEING 310 972 7303 P.02 equipment and setup required to measure to these tolerances would be fairly elaborate. Over time we I am hearing from our metrology group the tolerances as written in both regulations are too tight and the have corresponded with many third party labs and never determined any special setups, as described by our metrology, existed for their equipment and i have not heard of any rulings over this matter from D.O.T. or lATA authority. According to my contact in our Metrology group, when using Test to Accuracy have a measuring instrument that is +/- 0.2 to 0.5 %RH which leads to the not possible to the not Ratio (TAR), which should usually be 10:1 optimally but 4:1 is more realistic, we then are required to feasible when measuring in Humidity. What we see in our data shows, based on our recording equipment is calibrated to +/- 5 RH but both the digital and graphic presentation of our data has limited equipment calibration and configuration, that we are properly conditioning our fiberboard samples. Our resolution. Since the recorder is not calibrated to measure at +/- 2%, is our data qualified per the regulations? I believe these recordings to be typical in the industry. Our equipment also measures as coupled to a restrictions noted in CFR and lATA specifications. sensor that is very good at what it is specified for, but may be considered poor in relation to the sample conditioning for UN testing using calibrated equipment that has a limited calibration +/- 5% RH? Can you provide approval in writing that the data shown below is representative of acceptable fiberboard See attached actual recorded data indicating temp and humidity tolerance held within our environmental tolerance of +/- 5% humidity. We are running evaluations on our chamber and were looking for a chamber over a 24 hr period. This was recorded with our chart recorder calibrated to read with a qualified opinion as to whether these readings show we hold the tolerance required per Code of Federal Regulations Title 49 and/or IATA to provide UN qualified packaging. •Г Electron very sh this 3-71#

Page 4_ AUG-26-2002 11:33 BOEING 310 972 7303 P.03 Please review below additional 24 hr recording, particulary the Humidity, (circled areas which in my 5% humidity, but our equipment is calibrated for +/- 5% accuracy. opinion show swings in humidity between 3 & 4%. I consider these temporary fluctuations to be below 27:37 in humidity are limited to only 5%? If the equipment is not measuring to within the required +/- 2% humidity, how am I to determine swings Also how is "average" value calculated for this requirement as written In both regulations and when Is it acceptable to use a chart recorder and file these readings with the test report? Is this simply a visual interpretation for average? Vlust average be calculated or digitally converted? 6:56130505 Pa: (310) 902-72674 pager: 562) 872-9202 TOTAL P.03#