{"operation":"document","citation":"02-0318","title":"Honeywell — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-07-10","effective_on":null,"summary":"02-0318 response to Honeywell concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0318.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0318.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0318","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020318.pdf","body":"<<<PAGE 1>>>\n\n:\nU.S. Department\nof Transportation\nWashington, D.C. 20590\n400 Seventh St., S.W.\nSpecial Programs\nResearch and\nAdministration\nJUL 10 2003\nMs. Barbara Konrad\nRef. No. 02-0318\nManager, Transportation Safety\nHoneywell\nP.O. Box 1057\nMorristown, NJ 07962-1052\nDear Ms. Konrad:\nThis is in response to your letter, e-mail, and telephone conversation with Sandra Webb of my staff\nregarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to\nhermetically sealed sensing elements. Specifically, you request confirmation that the sensing elements\nonce incorporated into their final product, may be transported without being subject to the HMR. I\napologize for the delay in responding and hope it has not caused any inconvenience.\nAccording to your letter, each sensing elements is a copper metal capsule that contains approximately\n11 - 20 ml of certain flammable liquids and other gases listed below:\nToluene, 3, UN 1294, PG II\nEthyl ether, 3, UN 1155, PG I\nFlammable liquid, n.o.s. (Isopropyl alcohol), 3, UN 1993, PG III\nIsobutane, 2.1, UN 1969\nEthyl chloride, 2.1. UN 1037\nYou further state that most of the sensing elements in the group contain toluene. However, all of the\nmaterials listed above function as a temperature sensing fluid inside the element.\nYou question the following scenario:\nThe sensor elements are constructed (point A), \"aged\" and shipped to your assembly plant in\naccordance with the small quantity exception in § 173.4. At the assembly plant (point B), the\nsensor elements are incorporated into the final product. Each final product is placed in an\nintermediate packaging with cushioning and then placed into a strong, corrugated outer\npackaging and shipped to your distribution facility (point C). At the distribution facility, the\nouter packaging is broken down and the final products are placed with other non-hazardous\nmaterials and once again placed in a strong, corrugated outer packaging and shipped to\ncustomers (point D). In your opinion, because of the small quantities of hazardous materials,\nthe sensor design, construction, and protective packaging, the sensors in the final products\n\n<<<PAGE 2>>>\n\nshipped from point B to point C and point C to point D do not pose a significant hazard to\nhealth during transportation and, as a result, the sensors should not be subject to the HMR.\nBased on the information you submitted and the information available to us, the final products containing\nthe sensing elements are subject to the HMR for the following reasons:\nSmall quantities of Class 3, Division 4.1, Division 4.2 (PG II and III), Division 4.3 (PG II and\nIII), Division 5.1, Division 5.2, Division 6.1, Class 7, Class 8, and Class 9 materials that also\nmeet the definition of one or more of these hazard classes, are eligible for the small quantity\nexceptions in § 173.4. However, as noted, the Isobutane, 2.1, UN 1969 and Ethyl chloride,\n2.1, UN 1037 sensors are Division 2.1 flammable gases and are not eligible to be transported\nunder the small quantity exceptions in §173.4. These sensors must be transported as follows:\na.\nWith regard to the Isobutane sensor, it must be packaged in accordance\nwith §$173.306 or 173.304 as designated in column &A or 8B of the Hazardous Materials\nTable. However, you may take advantage of the limited quantities exception for compressed\ngases in § 173.306 provided all of the provisions are met. In addition, Isobutane packaged as\na limited quantity, in accordance with § 173.306, that meets the definition of a consumer\ncommodity may be reclassed as an ORM-D material and transported as a consumer\ncommodity.\nb.\nWith regard to the Ethyl Chloride sensor, there are no packaging exceptions\nauthorized in Column 8A of the HMT. Therefore, it must be packaged in accordance with\n§ 173.322 as designated in Column 8B of the HMT.\n2.\nWith regard to the Toluene, Ethyl ether and Flammable liquid, n.o.s. (Isopropyl alcohol)\nsensors, it is our opinion that they may be transported under the small quantity exceptions\nprovided the quantity of the Class 3 material in the inner packaging does not exceed thirty (30)\nmi and all other provisions of § 173.4 are met. However, you may choose to take advantage\nof the limited quantities exceptions for flammable liquids in § 173.150 provided all of those\nprovisions are met. In addition, if a flammable liquid is packaged as a limited quantity, in\naccordance with § 173.150, and meets the definition of a consumer commodity, it may be\nreclassed as an ORM-D material and transported as a consumer commodity.\nI trust this satisfies your request. If we can be of further assistance, please do not hesitate to contact us.\nSincerely,\nShain Drof\nSusan Gorsky\nSenior Regulation Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nNOU-21-2002 10:16\nP.01/03\nHoneywell\nHoneywell\nP.O. Box 1057\nWebb\nMorristown, NJ 07962-1057\n872.101.5\nVIA FAX (202) 366-3012\nApplicability\npages =3\n09-0318\nUS Department of Transportation\n400 of treet sious Materials Standards\nWashington, DC 20590\nAttention:\nED MAZZULLO, DHM-10\nRe:\nRequest For Clarification On Applicability Of HMR To Heretically-Sealed\nCopper Sensing Elements\nDear Mr. Mazzullo:\nHazarius Materials Regulations MR, 49C..R. Parts 7 80 i a giry t\nhermetically-sealed copper sensing elements that contain small quantities (< 20 ml) of\ntoluene or other fill materials. Because of the design, construction, and packaging of\nthis group of sensing elements, Honeywell believes that the hazardous materials\npresent in the elements do not pose a significant hazard to health during transportation\nand, as a result, that the group should not be subject to the HMR. The purpose of this\nletter is to describe the sensing elements and to seek clarification as to whether the\ngroup of elements is excepted from the HMR.\nDescription Of Sensing Elements. Each sensing element is a copper metal capsule,\nranging from 2 to 4 inches in length and from 0.375 to 0.50 inches in width. A small\namount (< 20 ml) of certain flammable liquids and/or gases (listed below) is introduced\ninto each capsule. After each sensing element is hermetically sealed, the element is\nsubjected to an aging process in which it is heated in an oven for 40 hours at\ntemperatures ranging from 115 to 190 degrees Fahrenheit. During this process, no\nhazardous materials are released from the element, nor is there deformation or\ndegradation of the element. The sensing elements cannot be broken apart absent the\ndeliberate use of a tool.\nThe vast majority of elements in the group contain toluene (3, UN1294, PG II), which\nfunctions as a temperature sensing fluid inside the element. The following fill materials,\nwith identical functions, also are contained in a minority of the sensing elements;\nEthyl ether, 3, UN1155, PG|\nFlammable liquid, nos (isopropyl alcohol), 3, UN1993, PG III\n• Isobutane, 2.1, UN1969\nEthyl chloride, 2.1, UN1037\n•\nHoneywell Temperature Sensor Interpretation Request Page 1\n\n<<<PAGE 4>>>\n\nNOU-21-2002\n10:16\nP.02/03\n-\nPackaging And Transport. The elements are offered for transportation by motor vehicle\nand cargo aircraft. As protection during transport, the sensing elements are first\nshipped in sturdy plastic bins. Once the elements are assembled into final products,\nthey are shipped in strong outer packages. Both the sensing elements and the plastic\nbins in which they are transported have passed drop tests from 1.8 meters. Additionally,\nall of the elements subjected to compressive load tests passed without incident. The\nhermetically-sealed sensing elements have passed these rigorous tests and cannot be\nopened absent deliberate use of a tool. Therefore, the risk is negligible that hazardous\nmaterials will be released from the elements under conditions normally incident to\ntransportation.\nConclusion And Summary. The design, construction, and shipment of Honeywell's\nclass of sensing elements remove virtually all risk of leakage during transport.\nHoneywell therefore believes that the class of elements can be transported safely\nwithout being subject to the HMR.\nFor your reference, we have attached a letter of clarification dated November 6, 2000, in\nwhich you determined that certain sealed glass tubes containing trace gases were not\nsubject to the HMR. We believe that the reasoning in that letter applies equally to\nHoneywell's group of sensing elements. Honeywell's sensors, in fact, are less\nhazardous to health during transportation because they are made of copper, not glass,\nand thus are effectively non-breakable.\nWe respectfully request that you confirm that Honeywell's group of elements is excepted\nfrom the HMR. We appreciate your attention to this matter. Should you have any\nquestions or require additional information regarding Honeywell's sensing elements,\nplease do not hesitate to call me at (973) 455-4009 or email me at\nbarbara.konrad@honeywell.com.\nBihu Knual\nBarbara Konrad\nAttachment\nHoneywell Temperature Sensor Interpretation Request Pago 2\n\n<<<PAGE 5>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh St., S.W.\nSpecial Programs\nResearch and\nAdministration\nJUL 1 0 2003\nMs. Barbara Konrad\nManager, Transportation Safety\nRef. No. 02-0318\nHoneywell\nP.O. Box 1057\nMorristown, NJ 07962-1052\n• Dear Ms. Konrad:\nThis is in response to your letter, e-mail, and telephone conversation with Sandra Webb of my staff\nregarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to\nhermetically sealed sensing elements. Specifically, you request confirmation that the sensing elements\nonce incorporated into their final product, may be transported without being subject to the HMR. I\napologize for the delay in responding and hope it has not caused any inconvenience.\nAccording to your letter, each sensing elements is a copper metal capsule that contains approximately\n11 - 20 ml of certain flammable liquids and other gases listed below:\nToluene, 3, UN 1294, PG II\n••.\nEthyl ether, 3, UN 1155, PG I\nFlammable liquid, n.o.s. (Isopropyl alcohol), 3, UN 1993, PG III\nIsobutane, 2.1, UN 1969\n•\nEthyl chloride, 2.1. UN 1037\nYou further state that most of the sensing elements in the group contain toluene. However, all of the\nmaterials listed above function as a temperature sensing fluid inside the element.\nYou question the following scenario:\nThe sensor elements are constructed (point A), \"aged\" and shipped to your assembly plant in\naccordance with the small quantity exception in § 173.4. At the assembly plant (point B), the\nsensor elements are incorporated into the final product. Each final product is placed in an\nintermediate packaging with cushioning and then placed into a strong, corrugated outer\npackaging and shipped to your distribution facility (point C). At the distribution facility, the\nouter packaging is broken down and the final products are placed with other non-hazardous\nmaterials and once again placed in a strong, corrugated outer packaging and shipped to\ncustomers (point D). In your opinion, because of the small quantities of hazardous materials,\nthe sensor design, construction, and protective packaging, the sensors in the final products\n\n<<<PAGE 6>>>\n\nshipped from point B to point C and point C to point D do not pose a significant hazard to\nhealth during transportation and, as a result, the sensors should not be subject to the HMR.\nBased on the information you submitted and the information available to us, the final products containing\nthe sensing elements are subject to the HMR for the following reasons:\n1.\nSmall quantities of Class 3, Division 4.1, Division 4.2 (PG II and III, Division 4.3 (PG II and\nIII, Division 5.1, Division 5.2, Division 6.1, Class 7, Class 8, and Class 9 materials that also\nmeet the definition of one or more of these hazard classes, are eligible for the small quantity\nexceptions in § 173.4. However, as noted, the Isobutane, 2.1, UN 1969 and Ethyl chloride,\n2.1, UN 1037 sensors are Division 2.1 flammable gases and are not eligible to be transported\nunder the small quantity exceptions in §173.4. These sensors must be transported as follows:\nWith regard to the Isobutane sensor, it must be packaged in accordance\nwith §$173.306 or 173.304 as designated in column 8A or 8B of the Hazardous Materials\nTable. However, you may take advantage of the limited quantities exception for compressed\ngases in § 173.306 provided all of the provisions are met. In addition, Isobutane packaged as\na limited quantity, in accordance with § 173.306, that meets the definition of a consumer\ncommodity may be reclassed as an ORM-D material and transported as a consumer\ncommodity.\nb.\nWith regard to the Ethyl Chloride sensor, there are no packaging exceptions\nauthorized in Column &A of the HMT. Therefore, it must be packaged in accordance with\n§ 173.322 as designated in Column 8B of the HMT.\n2.\nWith regard to the Toluene, Ethyl ether and Flammable liquid, n.o.s. (Isopropyl alcohol)\nsensors, it is our opinion that they may be transported under the small quantity exceptions\nprovided the quantity of the Class 3 material in the inner packaging does not exceed thirty (30)\nml and all other provisions of § 173.4 are met. However, you may choose to take advantage\nof the limited quantities exceptions for flammable liquids in § 173.150 provided all of those\nprovisions are met. In addition, if a flammable liquid is packaged as a limited quantity, in\naccordance with § 173.150, and meets the definition of a consumer commodity, it may be\nreclassed as an ORM-D material and transported as a consumer commodity.\nI trust this satisfies your request. If we can be of further assistance, please do not hesitate to contact us.\nSincerely,\nXusan Dook\nSusan Gorsky\nSenior Regulation Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 7>>>\n\nWebb, Sandra\nFrom:\nSent:\nKonrad, Barbara (MTO) [barbara.konrad@honeywell.com]\nTo:\nFriday, February 21, 2003 1:40 PM\nSubject:\nCc:\n'sandra.webb@rspa.dot.gov'\nSENSOR INTERP\nSchmolke, Colleen (MN10)\nHON ethyl chloride\nMPEG\nsensor insi...\nHON ethyl chloride\nLPEG\nsensor finl...\nSENSOR SMALL QTY\nPKG.JPG\nSandra,\nI understand your position on the sensors leaving our\nplexiglass bins being subject to the HMR (small quantity exception 173.4) but would like\nan opportunity to explain in\nfinal products.\ngreater detail why the HMR should NOT APPLY to the sensors once they are incorporated intr\nSENSOR TRANSPORTATION FLOW:\n*\nrigid fiberglass bins for\nSensors elements are constructed (point A), \"aged\" (see below) then placed into\ncontinue to ship these\nshipment to the assembly plant. You already have photos of the sensor elements. We will\nsensors, in the bins, in accordance with the small quantity exception in 49 CFR 173.4.\n*\nproduct.\nAt the assembly plant (point B) the sensor elements are incorporated into the final\nYou already have a\nphoto of the final product. These final products are wrapped in bubble wrap, placed into\na Honeywell product box\na distribution facility (point\n(cardboard)\nand then placed into an overpack (fibreboard box). These are then shipped to\nC)\nsensors from point B to point C\nA copy of this packaging is provided below. We do not believe the shipment of the\nshould be covered under the HMR.\npackaged final products are placed\nAt the distribution facility, the boxes are broken down and the individually\n(with other non-hazardous materials) an overpack (fibreboard box) for shipment to final\nbelieve the shipment of the sensors from point C to point D should be covered under the\ncustomers (point D).\nHMR.\nThe facts supporting the non-applicability of the HMR are these:\nSensors contain approximately 11 - 20 ml of hazardous material, a very small amount\nfor any hazardous material\nSensors are made of metal and are hermetically sealed.\nIt is virtually impossible\nto escape from the sensors under conditions normally incident to transportation.\nthem in an oven at either 115F\nPrior to shipment they are subjected to rigorous testing. This includes \"aging\"\nor 190F for a minimum of 40 hours. During this aging process, the sensors do not release\nany hazardous material and are\nnot deformed in any way. This would indicate that even in an upset condition during\ntransportation, hazardous material\nwould not be released.\nwrap cushioning surrounding\nThe final products (with the sensor inside) are packaged one to a box with bubble\nthe product. This is then placed inside a Honeywell product box.\nshipped to our distribution\nThese product boxes are packed 24 to a \"case\" (strong, solid fibreboard box). when\n1\n\n<<<PAGE 8>>>\n\nfacility.\nitems ordered by oux\nFrom the distribution facility, each individual product box is packed (with other\ncustomers) into a new overpack (strong, solid fibreboard box) and shipped to the customer.\nHere are photos of the :\nbubble wrapped sensor\n<<Bubble wrapped sensor. JPG>>\nthe product box (containing the bubble wrapped sensor)\n<<HON sensor product box. JPG>>\nthe overpack into which the product boxes are placed for shipment\n<SENSOR OVERPACK. JPG>>\nbecause of the small quantities, the\nI hope this provides you with the additional information you need to determine that\nsubject to the HMR.\nsensor designs and the protective packaging, the sensors in the final products are not\nSo any hay ne can to desire ate give so ana to no can discuss.\nI appreciate your\nBarb\nManager, Transportation Safety\nBarbara Konrad\n973-455-4009 (phone)\n617-344-3093 (fax to PC)\n973-722-2574 (cellular)\n973-455-3491 (alternate fax)\n2\n\n<<<PAGE 9>>>\n\n\n\n<<<PAGE 10>>>\n\n-\n\n<<<PAGE 11>>>\n\n\n\n<<<PAGE 12>>>\n\n\"...\n*\n\n<<<PAGE 13>>>\n\n=\nHoneywell\nHoneywell\nP.O. Box 1057\nMorristown, NJ 07962-1057\nVia e-mail: sandra.webb@rspa.dot.gov\nDecember 19, 2002\nAssociate Administrator for Hazardous Materials Safety\nResearch and Special Programs Administration\nUS Department of Transportation\n400 7th Street, SW\nWashington, DC 20590-0001\nAttention: SANDRA WEBB - INTERPRETATIONS\nRe: Photos of Toluene Sensors and Shipping Bins\nAs a follow up to Honeywell's request for a formal interpretation on the applicability of\nthe Hazardous Máterials Regulations (HMR) to hermetically sealed sensing elements, we\nare providing photos of the sensing elements, the shipping bins and the final product\nwhich contains the sensing element.\nTHIS IS A PHOTO OF THE SENSING ELEMENT AT\nMANUFACTURING FACILITY\nThe toluene is contained in the 3\" long capsule in the left\nof the photo. These sensors are loaded into plastic bins\n(with covers) for shipment to final assembly facility. There\nthe parts are incorporated into\nthe final temperature sensing /\ncontrol device.\nThese are the plastic bins into\nwhich are placed the\ntemperature sensors. The\ncovers at then snapped into\nplace before shipping to the\nfinal product assembly location.\n\n<<<PAGE 14>>>\n\n•\nHoneywell International Request for Interpretation - Toluene Sensor Follow-up Page 2\nEach tempertaure sensor is assembled into the final\nproducts, individually boxed within final product\npackaging, and then shipped to a distribution\ncenter for shipment to customers.\nThe distribution center overpacks these devices into\nfibreboard boxes, usually with other non-regulated\nitems.\nHOHEKNEEL\nAs a separate attachment to this e-mail, I am including the pdf engineering\nspecification for the toluene sensors, which is identified as \"ES05142\".\nI hope that this additional information is helpful. We look forward to hearing of your\ndecision that these sensors are not subject to the HMR because they (1) contain such\nsmall amounts of hazardous material; (2) are constructed of solid, leak-proof metal;\nand (3) are over packed for shipment in either leak-proof plastic bins or in fibreboard\nboxes.\nShould you require any additional information, please don't hesitate to call me at 973-\n455-4009 or via e-mail at barbara.konrad@honeywell.com.\nHappy Holidays!\nBarbara Konrad\nManager, Transportation Safety\n\n<<<PAGE 15>>>\n\n•\nHoneywell International Request for Interpretation - Toluene Sensor Follow-up Page 2\nCc:\nColleen Schmolke\n\n<<<PAGE 16>>>\n\n.. r\nHoneywell International Request for Interpretation - Toluene Sensor Follow-up Page 2\n\n<<<PAGE 17>>>\n\n-\n•\nHONEYWELL\nNo. E$ 15042\nENGINEERING SPECIFICATION\nSOLD FILLED DIAPHRAGM TYPE SENSING ELEMENTS\nPage 1 of 4\nCurrent Issure Date:\n11/30/93\nReleased to Production:\nDISTRIBUTION\nOriginal Issue Date:\n11/30/93\nSupersedes:\n04/23/85\nMEXICO\nARLHIS\nTOKYO\nX\nDevelopment No.\nTORONTO\nAPPROVAL\nDATE\nDESIGN MANAGER (Section I):\nPROCESS MANAGER (Section II):\nD. M. Saunderson\nD. M. Putnam\nQUALITY MANAGER:\nREVIEWED BY:\nREVISION HISTORY\nDATE\nPAGES\nPAGES\nPAGES\nECO\nREVISED\n11/30/93\nRevised &\nRetyped\nSupersedes\nDATE\nECO\nREVISED\nDATE\nECO\nREVISED\n92-1189\n04/23/85\n•\nNo. ES 15042\nPage 1 0f4\nED'd\n0500067-40-2\n\n<<<PAGE 18>>>\n\n•\n...\n• •\nHONEYWELL\nENGINEERING SPECIFICATION\nNo. ES 15042\nSOLI FILLED DIAPHRAGM TYPE SENSING ELEMENTS\nPage 2 of 4\nSECTION I - GENERAL DESIGN SPECFICATIONS\nCurrent Issue Date 11/30/93\nA. General Description of Device\ncompletely filled with a termal sensing fluid which expands with an inorease in temperature. This\nvolume increase in the tluid causes the diapbragm of the element to have its \"Travel.\"\nThe specific characteristics of the elements are set forth in tabulation form on the element prints.\nB. Definition of Terms\n• The ranges listed on the element prints are not necessarily the limits of the clements but could be\n• The nominal diaphragm travel per degree F of change in temperatute at the capsule is a reference\nthe limits of the requirements of the device for which an element is intended.\nvalue and is not to be checked.\n• The active temperatute is the temperature at which the diaphragm will not be more than 030\"\nbelow the standard reference position taking into consideration the diaphragm position tolerance\nstop by the bottoming of the diaphragm housing.\nunder filling conditions. At this temperature, the diaphragma must still be free to travel and not\n• The maximum temperature is the highest temperature to which the clement should be subjected.\nand/or a shortening in the life of the diaphragt if cycled to these temperatures.\nHigher temperatures could cause a calibration shift in the device to which the olement is applied\n• The maximum deflection at the maximum temperature is the travel above the standard reference\nposition at this temperature. It is calculated from the clement travel and the diaphragm position\nthe maximum deflectión is also for information purposes and not to be checked.\nand tolerance under fill conditions. The diaphragm travel per degree is a reference value and so\n• Deflection is the perpendicular distance, the center flat portion is moved from this plane.\nobserved without diaphragm load.\nDeflection toward the housing is considered to be negative and away from the housing positive.\nPAAN: BARBARA KONRAD\nFRoM: COLEN SCHMAKE\n0.0031 gallons Toluene/capsule =1173mL Toluene 882062\nTØ'd\n20006-20-2\n\n<<<PAGE 19>>>\n\nMAR-07-1900\n01:31\nP.09\n1P1. YAS,\nGOKAXIO\nMULS\n7\nRE\nPRAY\nS4NDODS\nK m D8tL1\nf1211ng,\nFOLION\nD$ 5362 fo5\nREVISION\"\nTKIS-\n123914 Opnie\nStoche\nID.\ntolun\n5:/34\nB-1\n7-1/47\n- 30\n399₴\nAvastid Capsúle -\n(130)\nsungaid Coprele -(125563\n• = Top Connectirg Capillary\"\nCapillary\nrasopoly datali.\n/honge Scry fut/te/swar(197002-Kes:)\nHư I\n- Top Gonaşteing Capillary & Welded Pad.\nDN: 137986\nNESB\n(123914. Rgf.)\n...\n• stalacton of the codes\nN\nt02.\n43.\n16\"\n150 2.\nDALBUE ANSEOLI\ncopper.\nDoppe\nсеррат\ncopper\nCATILINRY\nSse CAn tate e 11e. and f411 tube)\nTare d 11a ( 2l fuge eo outa orle:\nSUPERSEDE5\n.O-KD.\nSUPERSEDEO BY\n0° t0110%\n30* to 190°g\n30\" to 220 3\n40\" tD 100*T*\nto 70°g\n• 60° to 200 T\n110° ка 290°г\n10 NG 246°g\nCopper\nCorrec (heterdaa\nTõr ardstlos DE a torsth. Irtbe: W111 Ledicta & connlete 21lled andesały appltcable\nthe adeltfen of lettero fiom n oode WiL be ueed de itticate sat cenatscucia cRe.\n120 to 950%. A\nto. 100 F\no2 ly)\nThala sualier uitb ebraz, legtara wLI1 Indicate e complate ansensly aszorE\nдаке\n11-22-55°\nRATE 2-25-69 DRENAHE SON AEd ON\nARDBAR1\n# INACTIVE\n- 248\" Coypst\n- 124\" Copper\n\" Ii coppet\nWith lean, chars threz letterz, thin rooker mosne nathiog.\n•HONEYWELL INC.\n21-2/4\"Coрдer\n33-1/4 Copper\n- 39-1/4 Сорявс\n4-1/44 соррос\n[EFAND 2\" HIN\nESASED .CAPSULE-(125583\n- 35-3/8* соурок (яна оліт,\n108032XXXX\n10 4436\n.D2 $362\na o-E0\nA0 3-31-878083-160\nLAS 2-17-5424-309\n14005\nSEL. Mad\nFILL TINE\nToluene\nTOTAL P.09\n\n<<<PAGE 20>>>\n\n...€\n-\n:\nHONEYWELL\nENGINEERING SPECIFICATION\nNo. ES 15042\nSOLID FILLED DIAPHRAGM TYPE SENSING ELEMENTS\nPage 4 of 4\nSECTION II - FACTORY SPECIFICATIONS\nCurrent Issue Date 11/30/93\nA. Process Requirements (cont.)\n3. Instructions for Filling (cont.)\ncotion in Ta craving a min a sea do care a into me pump times:\nMinimura time - 8.0 × 10-6 VL\nwhere:\ntime is in minutes\nvolume la cubic inches of the inside volume of the capillary plus the volume of\nthe system to be evacuated through the capillary\nhe inside diameter of the capillary in inche\nhe length of the capillary in inche\nNote: Use nominal piece part dimensions for this calculation.\nd. Seal fill tube per element print.\n4. Aging of Filled Elements\n%. Regical element that do not me to diplingm defection at standard emperature\n•\n•\n:\nNo. ES 15042\nPage 4 of 4\nBE:10\n06-L0-\n\n<<<PAGE 21>>>\n\nDEC-19-2002 10:51\nP.01/02\nHoneywell'\"\nP.O. Box iOST. .\nHoneywell-\nMomstown, NS - 07962-1057\n202-366-3012\nVia e-mail: sandra.webb@rspa.dot.gov\nFax = 2 pages.\nDecember 19, 2002\nAssociate Administrator for Hazardous Materials Safety\n.. Research and Special Programs Administration\nUS: Department of Transportation\n400.74\n• Street, SW\nWashington, DC 20590-0001\nAttention: SANDRA WEBB - INTERPRETATIONS)\nRe:\nPhotos of Toluene Sensors and Shipping Bins\n... Aș.a follow up to Honeywell's request for a formal interpretation on the applicability of\nthe Hazardous Materials Regulations (HMR) to hermetically sealed sensing elemerits,\nwhich contains the sensing element.\nwe are providing photos of the sensing elements, the shipping bins and the final product\nTHIS IS A PHOTO OF THE SENSING ELEMENT AT MANUFACTURING FACILIȚY.\nThe toluene is contained in the 3\" long capsule in the left of\nthe photo. These sensors are loaded into plastic bins (with\ncovers) for shipment to final assembly facility. There the\nparts are incorporated into the final temperature sensing /\ncontrol device.\nThese are the plastic bins intó\nwhich are placed the\ntemperature sensors. The\ncovers at then snapped into\nplace before shipping to the\nfinal product assembly location.\n\n<<<PAGE 22>>>\n\nDEC-19-2002\n10:51\nP:02/82\nHoneywell International Request for Interpretation - Toluene Sensor Follow-up Page.2:\nEach tempertaure sensor is assembled into the final\nproducts, individually boxed within final product\npackaging, and then shipped to a distribution; center.-\nfor shipment to customers.\nThe distribution center overpacks these devices into\nitems.\nfibreboard boxes, usually with other non-regulated..\"\nAs a separate attachment to this e-mail, I am including the pdf engineering specification\nfor the toluene sensors, which is identified as \"ES05142\".\nI hope that this additional information is helpful. We look forward to hearing of your\ndecision that these sensors are not subject to the HMR because they (1) contain such\nsmall amounts of hazardous material; (2) are constructed of solid, leak-proof metal; and\n(3) are over packed for shipment in either leak-proof plastic bins or in fibreboard boxes.\nShould you require any additional information, please don't hesitate to call me at 973-\n455-4009 or via e-mail at barbara.konrad@honeywell.com.\nHappy Holidays!\nBarbara Konrad\nManager, Transportation Safety\n.. ;\n-.Colleen Schmolke.\n:..:\n' : .\n-\nTOTAL P.02\n**","truncated":false,"body_characters":27536}