{"operation":"document","citation":"02-0224","title":"Boeing - Long Beach Division — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-10-28","effective_on":null,"summary":"02-0224 response to Boeing - Long Beach Division concerning 178.602.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0224.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0224.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0224","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020224.pdf","body":"<<<PAGE 1>>>\n\n•\n5. Departmer\nTransportatic\nWashington, S\n20590\nspecial Programs\nAdministration\nОСт 2 8 2002\nMr. Scott W. Chapman\nBoeing - Long Beach Division\nRef. No. 02-0224\n19270 Western Avenue\nTorrance, CA 90501\nDear Mr. Chapman:\nThis is in response to your August 26, 2002 letter concerning package testing requirements under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you requested\nclarification concerning the relative humidity requirements for testing paper and fiberboard packagings\nin § 178.602. You state that while the HMR requires margin of error of +2% in determining relative\nhumidity, the machine you use has a margin of error of 15%.\nSection 178.602 (d) requires the packaging to be maintained at least 24 hours prior to testing in an\nto a 15% deviation (45% or 55% relative humidity) for short term fluctuations in this minimum 24-hour\nenvironment with 50% relative humidity, plus or minus 2%. In addition, the requirements allow for up\nperiod. The average relative humidity would be calculated for at least 24 hours before the test, and\nwould allow for ‡5% deviation spikes, but the average relative humidity must remain between 48% and\n52%.\nYou equipment will need to be accurate enough to ensure that the pre-test environment falls within\nthese specifications. Your equipment and subsequent data display may be of any number of\ntechnologies or styles, but it is the responsibility of the equipment owner to be able to read and verify\nthat the packaging was in an environment that meets these criteria for at least 24 hours prior to testing.\nIf you feel this criteria is too restrictive, then you may petition RSPA for a change to the regulations\nunder the process outlined in § 106.31 of the 49 CFR.\nI hope this satisfies your request.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n178.602\n020224\n\n<<<PAGE 2>>>\n\n• AUG-26-2002 11:33\nBOEING\n310 972 7303\nP.01\n@BOEING:\nJohnsen\nA Division of McDonnell Douglas Corporatior\nLong Beach Division,\nA Wholly Owned Subsidiary of The Boeing Company\n$178.602\nTorrance, California 90501\n19270 Western Avenue\nPACKAGING ENGINEERING\nlesting\nAugust 26, 2002\n02-0924\nTo Edward T. Mazzullo:\nI was hoping you could give me a response in writing that our humidity tolerances maintained by our test\nrequirement for IATA and CFR49 below.\nequipment are acceptable as recorded for our fibreboard sample conditioning. See excerpted\nJATY\nDangerous Goods Ragulations\n80 long as thay. ara piaded so hat the test resulls are not\ninvalldated.\n322 l te dr faste for liquide, when another\n(specific gravity) and viscosity should be similar to 1h03e.of\nsubslance is used, it must be of similar relative density\nthe substance being transported. Wasor may also be usad\n6.9.3.4.\nfor the lauld drop test under the conditions set lorth in\n83.27:: Pip\ntomboard\nsk her dondl\nĐho\nhe/was must all within chaselims, Shot.\non inha\nnot capital\nrelate\n§178.602\nPreparation of packagings and packnges for resting\nsting and resis must be carriod our in the samt manner as if propared, for bansporatión, inaluding inner packaginga\n) Excopi as utharwise provided in this subehapter, each prokaging and paclonge maar da oldeed in preparation f\ntho ceso of combinailon packuginge.\nfor chamical compalbility resting or wirre this would invalidate the results of the tesis.\nbe of the same or higher specific gravity as the matotial to be carried, and its other physical propertiós Cerain, size, viscos.\n(e) If tbe Distarial to be transported is replaced for test ptuposes by a non- hazardous material, tha material used must\nity) which might influence be results of tho required tests must curiospond as clodely ds positile to rhose of the hazard.\n;178.603(e) of this subpart. It is permissible to use ndditives. auch as bags of lead shot, to achieye the roquiaite total park.\nus tasterial to be transported. Wards may sisu bo aeed for the liquid drop cas under the conditions specified in\nago mass, to long as they are placed so that the test results are not affected.\nsphere invintained—\n(d) Paper or fiberboard packagings must be conditioned for at least 34 houra immediately prior to besting in an ntmo.\nare tastes tales and measurement limicalion may cauda individual incuxurements\n(1) du SD pescent = 2 percent rolntire humidiry, and at a lemperaturo of 23° C= 2° C (73° Ft 4° F), Average values\nto vary by up o= 5 paicent relative humidity will signifieant impoirment of bost reproduciblity:\n(81° Fg4° 1). Averace valies shuald tall withie these limits, Short-torm Doctuations and raessurement limitations m*\n2) At 65 percent + 2 pezernt colative humidiry, and nt a lemberrue of 20º C* 20C 9[=40M*C+?\ncause individual measureinenes to Vary by up lo = 5 percent relative humidity without significont impair ment of test\n(3) For resting at periodic intervals only G.e., arher thon initiat design qualification resting), at arbient conditions.\n\n<<<PAGE 3>>>\n\n„AUG-26-2002 11:33\nBOEING\n310 972 7303 P.02\nequipment and setup required to measure to these tolerances would be fairly elaborate. Over time we\nI am hearing from our metrology group the tolerances as written in both regulations are too tight and the\nhave corresponded with many third party labs and never determined any special setups, as described\nby our metrology, existed for their equipment and i have not heard of any rulings over this matter from\nD.O.T. or lATA authority. According to my contact in our Metrology group, when using Test to Accuracy\nhave a measuring instrument that is +/- 0.2 to 0.5 %RH which leads to the not possible to the not\nRatio (TAR), which should usually be 10:1 optimally but 4:1 is more realistic, we then are required to\nfeasible when measuring in Humidity. What we see in our data shows, based on our recording\nequipment is calibrated to +/- 5 RH but both the digital and graphic presentation of our data has limited\nequipment calibration and configuration, that we are properly conditioning our fiberboard samples. Our\nresolution.\nSince the recorder is not calibrated to measure at +/- 2%, is our data qualified per the regulations?\nI believe these recordings to be typical in the industry. Our equipment also measures as coupled to a\nrestrictions noted in CFR and lATA specifications.\nsensor that is very good at what it is specified for, but may be considered poor in relation to the\nsample conditioning for UN testing using calibrated equipment that has a limited calibration +/- 5% RH?\nCan you provide approval in writing that the data shown below is representative of acceptable fiberboard\nSee attached actual recorded data indicating temp and humidity tolerance held within our environmental\ntolerance of +/- 5% humidity. We are running evaluations on our chamber and were looking for a\nchamber over a 24 hr period. This was recorded with our chart recorder calibrated to read with a\nqualified opinion as to whether these readings show we hold the tolerance required per Code of Federal\nRegulations Title 49 and/or IATA to provide UN qualified packaging.\n•Г\nElectron\nvery sh\nthis\n3-71\n\n<<<PAGE 4>>>\n\n_ AUG-26-2002 11:33\nBOEING\n310 972 7303\nP.03\nPlease review below additional 24 hr recording, particulary the Humidity, (circled areas which in my\n5% humidity, but our equipment is calibrated for +/- 5% accuracy.\nopinion show swings in humidity between 3 & 4%. I consider these temporary fluctuations to be below\n27:37\nin humidity are limited to only 5%?\nIf the equipment is not measuring to within the required +/- 2% humidity, how am I to determine swings\nAlso how is \"average\" value calculated for this requirement as written In both regulations and when\nIs it acceptable to use a chart recorder and file these readings with the test report?\nIs this simply a visual interpretation for average?\nVlust average be calculated or digitally converted?\n6:56130505\nPa: (310) 902-72674\npager: 562) 872-9202\nTOTAL P.03","truncated":false,"body_characters":7919}