Baker Hughes — Hazardous Materials Safety Interpretation

Page 1Washington, D.G. 20590 400 Seventh St., S.W. WAR 19 2008 Mr. John W. Miggins Product Safety/Transportation Specialist Reference No.: 03-0039 Baker Hughes 12645 West Airport Boulevard Sugar Land, Texas 77478-5050 Dear Mr. Miggins: This is in response to your letter requesting clarification of the packaging requirements in § 173.226(b) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Division 6.1, Packing Group I, Hazard Zone A material. You state that the DOT 4BW cylinder Specifically, you ask if a 54 gallon DOT 4BW cylinder may be used as an inner packaging for a meets or exceeds the performance standards of a 1A1 steel drum which is an authorized inner packaging. The answer is no. Section 173.226(b) does not authorize a DOT 4BW cylinder as an inner packaging. The drums authorized as inner packagings in § 173.226(b), as well as the outer at the Packing Group I performance level. A DOT 4BW cylinder is manufactured to a specific drums, must conform to the performance test requirements of subpart M of part 178 of the HMR design specification instead of a performance standard. Therefore, use of a DOT 4BW cylinder as the inner packaging of a UN 1A1 drum for a Hazard Zone A material must be authorized I trust this satisfies your inquiry. Sincerely, Hotte z. mithall Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Material Standards 030039 113722 35202#

Page 21-12-03 02:17pm From-Baker Patrolite 281 275 7209 T-311 P.002/002 F-950 Corbin 3173,226 (b) Packuging Specs BAKER HUGHES Baker Petrolite 03-0039 P. O. Box 5050 February 12, 2003 Tel 281-276-5400 Sugar Land, Texas 77478-5050 Mr. Edward T. Mazzullo Fax 281-275-7385 Director, Office of Hazardous Materials Standards 400 7th Street S.W. U.S. DOT/RSPA (DHM-10) Washington, D.G. 20590-0001 Mr. Mazzullo: great deal of debate among my colleagues regarding the use of a 54 gallon 4BW I am requesting a letter of interpretation regarding 173.226(b). There has been a Cylinder as an inner drum to be over packed with a customized drum regulation that will explain whether or not we can utilize a welded cylinder that manufactured to 1A2 specifications. We are seeking interpretation of the above may meet or exceed the safety requirements of a 1A1 drum as an inner drum to be over packed in a 1A2 drum; thus would be exempt from the requirements in 173.226(a). Please fax me (281-275-7385) or email me (john.miggins@bakerpetrolite.com) your letter of interpretation. Thank You, John W. Miggins Product Safety/Transportation Specialist#