{"operation":"document","citation":"02-0264","title":"First Filtration International Co., Ltd. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-02-13","effective_on":null,"summary":"02-0264 response to First Filtration International Co., Ltd. concerning 173.199.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0264.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0264.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0264","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020264.pdf","body":"<<<PAGE 1>>>\n\nFEB 1 3 2003\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nSpecial Programs\nResearch and\nWashington, D.C. 20590\nAdministration\nMr. Alastair Hayton-Williams\nSales and Marketing Consultant\nReference No. 02-0264\n37/2 Moo 9, Sukhumvit Road\nFirst Filtration International Co., Ltd.\nBanglamung, Chonburi\n20260 Thailand\nDear Mr. Hayton-Williams:\nThis is in response to your letters and additional information concerning your product, the Aqui-\nPak pouch. You described the product as being made of a multi-layered, absorbent, disposable\npolymeric material. You state that the pouch provides separation, absorption and cushioning in\none product and can be used as the secondary packaging for liquid primary receptacles. You also\nstate that a liquid upon contact with the polymeric material is completely absorbed and becomes\ninconvenience this may have caused.\na gel. We have paraphrased your questions. We apologize for the delay in responding and any\nQ1.\nMust our Aqui-Pak pouch be tested by the Research and Special Programs\nagnostic specimen under the Hazardous Materials Regulations (HMR; 49 CFR Part\ndministration (RSPA) or other company to be approved as a packaging component for\n171-180)?\nAl.\nThe answer is no. The secondary packaging is not required to be tested as an individual\ncomponent but as part of the complete packaging. RSPA does not test or certify\nhazardous materials packagings.\nIn a recently published final rule, we adopted new § 173.199 to the HMR to permit a\ndiagnostic specimen other than Risk Group 4 to be transported in a non-DOT\nand an outer packaging (Docket No. RSPA-98-3971 (HM-226), August 14, 2002, copy\nspecification triple packaging consisting of a primary receptacle, a secondary packaging,\nenclosed). This section requires that the primary receptacle and the secondary packaging\nbe properly packed and secured and that the secondary packaging be leakproof. The\ncompleted packaging must also be capable of passing a 1.2 meter (3.9 feet) drop test as\nprescribed in § 178.603. If intended for the transport of liquids by aircraft,\n§ 173.199(b)(4) requires that the primary receptacle or secondary packaging be capable of\nwithstanding, without leakage, an internal pressure producing a pressure differential of\nnot less than 95 kPa (0.95 bar, 14 psi). It is the shipper's responsibility to ensure that the\npackaging or container is an authorized packaging and meets all applicable requirements.\n173.199\n020264\n\n<<<PAGE 2>>>\n\nA Risk Group 4 diagnostic specimen must be classed and transported as a UN 2814 or\nUN 2900 infectious substance in a packaging tested and marked as required by § 173.196\nand § 178.503(f), respectively. See §173.134(a)(4). The new requirements become\neffective February 14, 2003; however, voluntary compliance is authorized.\nQ2.\nOur Aqui-Pak pouch conforms to Packing Instruction 650 of the International Civil\nAviation Organization's Technical Instructions for the Transport of Dangerous Goods by\nA2.\nIf, as you state, the combination packaging containing the Aqui-Pak pouch conforms to\nthe completed secondary packaging must meet all applicable requirements.\nPacking Instruction 650 of the ICAO Technical Instructions, the answer is 10. However,\nI hope this satisfies your request.\nSincerely,\nWhite 2. Mitshelf\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Regulation\nEnclosures\n\n<<<PAGE 3>>>\n\nPage 1 of 2\nINFOCNTR\nFrom:\nAlastair [eightwestfour@hotmail.com]\nSent:\nWednesday, October 02, 2002 1:39 AM\nTo:\nInfocntr, Infocntr <RSPA>\nEdmonson\nSubject: Fw: OHMS\\Aqui-Pak\n-§/73.34199\nRedugnoshe Specumen =\nsorry! Last letter sent without attachments.\nMr. Edward T. Mazzullo\n02-0264\nMs. Susan gorsky\nOffice of Hazardous Materials Standards\nU.S. DOT/RSPA (DHM-10)\n400 7th Street S.W.\nWashington, D.C. 20590-0001\nDear Mr. Mazzullo and Ms. Gorsky,\nTransportation of Diagnostic Medical Specimens\nWe are writing to you as we would greatly appreciate your advice and assistance concerning\na material used for transporting hazardous liquids, serum and medical specimens.\nYou can\nsee on our web-site the most recent article concerning Safebox and the Royal Mail (Great\n3ritain). We manufacture the insert for Safebox - Aqui-Pak. Aqui-Pak is a super-absorbent\nincluding blood and urine. This concept is of immense interest to those concerned with safety\ndisposable material for the sate transportation of hazardous liquids and diagnostic specimens,\ninvolved in taking and transporting samples. You can also see the magazine in which our\nin the courier and mailing companies, medical and veterinary professions and to anyone\npress release was published\nand photographs of both Aqui-Pak and Safebox on our Web-\nsite.\nThere is strong interest in this product from companies in USA, and we would very much like to\nknow if our material has to be tested by you, or whether it is tested in conjunction with the\nouter packaging supplied by the client company.\nThe material was developed following requests from couriers and the postal service in Great\nstations although there are many other applications and uses. No doubt you may have other\nBritain for use by hospitals; laboratories, drug and alcohol testers, veterinarians and police\nideas. The pouch form costs only a few US cents.\nThe directive P650 is also on our web-site, which relates to UN 3373 concerning packaging\nspecifications, particularly by allowing the four samples to be places alongside each other yet\nmaterials used in the transportation of diagnostic specimens. Aqui-Pak conforms to these\nseparated in the totally absorbent pouch. As such, do we need to take any further steps?\n10/2/02\n\n<<<PAGE 4>>>\n\nPage 2 of 2\nOur new web address is www.firstfiltration.com\nThank you for your assistance.\nYours sincerely\nAlastair Hayton-Williams\nSales and Marketing Consultant\nFirst Filtration International Co. Ltd.\n10/2/02","truncated":false,"body_characters":5880}