{"operation":"document","citation":"03-0025","title":"HAZMATPAC Certified Packaging — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-07-11","effective_on":null,"summary":"03-0025 response to HAZMATPAC Certified Packaging concerning 173.27.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0025.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0025.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0025","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030025.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nJUL 11 2003\nMr. Donald H. Hausmann\nReference No.: 03-0025\nHAZMATPAC Certified Packaging\n5301 Polk Street, Building 18\nHouston, Texas 77023\nDear Mr. Hausmann:\nThis is in response to your January 29, 2003 letter requesting clarification of the requirements in\n§ 173.27(e) in the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) and the exception\nin that section which states:\n\"Absorbent material is not required if the inner packagings are so protected that\noccur during normal conditions of transportation.\"\nbreakage of them and leakage of their contents from the outer packaging is not likely to\nIn general terms, absorbent materials are not required when a material specified in the first sentence of\n§ 173.27(e) is offered for transportation in a UN standard package which meets the applicable\nperformance tests in the HMR. One exception would be if absorbent material is specifically required\nby the packaging instructions applicable to the hazardous material contained in the packaging. See for\nexample, the ICAO Technical Instructions, Packing Instruction 304, particular packing requirements 6\nand 13 which require the use of absorbent material without exception. A second exception is where\nthe actual \"normal conditions of transport\" which the package may experience are not adequately\naddressed by the performance tests associated with a particular UN standard. As stated in 49 CFR\n178.601(a), the performance test procedures \"are considered minimum requirements\" and \"each\npackaging must be manufactured and assembled so as to be capable of successfully passing the\nprescribed tests and of conforming to the requirements of § 173.24... at all times while in\ntransportation.\" If packages experience particularly harsh treatment in a distribution system which\n030025\n\n<<<PAGE 2>>>\n\nmay result in breakage or leakage, even though the packages have passed UN performance tests,\nabsorbent material may be necessary to ensure that the effectiveness of the packaging is not\nsubstantially reduced and there is no release of the hazardous material from the outer packaging.\nFurther clarification on the use of absorbent material will be addressed in a future rulemaking.\nI hope this satisfies your request.\nSincerely,\nedmand 1. Branzul\nEdward T. Mazzullo\nDirector, Office of Hazardous Materials\nStandards\n\n<<<PAGE 3>>>\n\nHAZMATPAC®\nBetts Webb\nCERTIFIED PACKAGING\n$113.2719\n5301 POLK STREET, BLDG. 18\nwww.HAZMATPAC.com\nHOUSTON, TEXAS 77023\nlackagings\n713.923.2222\n1.800.923.9123\nJanuary 29, 2003\n03- 0025\nFAX 713.923.1111\nOffice of Hazrdous Material Standards\nMr. Edward T. Mazzullo\nResearch and Special Programs Administration\nDepartment of Transportation\n400 Seventh St. SW, Room 8321\nWashington, DC 20590-0001\nDear Mr. Mazzullo,\nI am requesting a written response to this letter. In the section 173.27 section (e) states\n\"Absorbent material is not required if the inner packagings are so protected that breakage of\nthem and leakage of their contents from the outer packaging is not likely to occur under normal\nconditions of transportation\".\npackage is safe for transport and inner container cannot breakage and still pass the test, does\nKnowing the basic reason or justification for the United Nations testing is to determine if a\nit not stand for reason that if a packaging passes the United Nations testing then it would meet\nthe criteria to not require absorbent material.\nallow a packaging to meet the criteria, why are these tests not currently required to pass the\nIf not, what additional testing would meet this requirement. If some additional testing would\nUnited Nations objective of safe transport.\nrequirements and passes without absorbent material, does the passing of the test allow for the\nTo restate my question \" If a package is tested to meet the United Nations performance\nelimination of absorbent material for air shipments?\".\nIf it does not, my next question is \"What additional tests are required to meet the elimination of\nabsorbent material for air shipments?\".\nIf additional testing would be required for meets the elimination of absorbent material, \"why are\nthese tests not currently required for all United Nations testing?\".","truncated":false,"body_characters":4302}