Lansmont Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department JUN 24 2003 400 Seventh St., S.W. Washington, D.G. 20590 Research and Special Programs Administration Ms. Tramy Lieu 1287 Reamwood Avenue Lansmont Corporation Reference No.: 03-0090 Sunnyvale, CA 94089 Dear Ms. Lieu: This responds to your letter requesting clarification of the requirements for testing of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions pertain to a 4G combination packaging with a glass inner packaging that contains a PG I liquid kilograms. Your questions are paraphrased and answered as follows: with a specific gravity (SG) of 1.7. The gross weight of the combination packaging is 14.3 Q1. The packagings are drop tested from a height of 2.6 m, calculated per § 178.603(e) (2)(i)(A) with water replacing the hazardous material. Must the packagings be drop tested at the gross weight of 14.3 kg? A1. The answer is no. The increased drop height is used to simulate the higher specific gravity. Q2. May water be used in lieu of the hazardous material in the vibration test? A2. Yes, water may be used to perform testing to determine if a non-bulk packaging is capable of passing the vibration standard. Q3. Does 49 CFR contain a formula for calculating the maximum gross weight of a package if the specific gravity and drop height are defined. A3. The answer is no, there is no formula to calculate the maximum gross weight of a package if the specific gravity and drop height are defined. The drop height is based on he packing group and specific gravity of the material, not on "gross package weight. 'he maximum gross weight that may be marked on a package is based on meeting th required performance test standards, however, the maximum gross mass would be the combined weight of the liquid and the weight of all inner and outer packagings. 030090 178.60l .....:#

Page 2I trust this satisfies your inquiry. Sincerely, Hothe z. Mitched Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Corbin Lansmont 8178.601(() Corporation Testing 03-0090 Mr. Edward Mazzullo Director, Office of Hazardous Materials Standards 400 7" Street S.W. US.DOT/RSPA (DHM-10) Washington, DC 20590-0001 March 24, 2003 Dear Mr. Mazzullo, bottle as the inner packaging, packing group I, specific gravity 1.7, gross weight 14.3 Please clarify for me the 4G Combination package containing liquid content & glass kg For the preparation for drop test: 1. Glass bottle is filled with water. 2. Drop at 1.5m x 1.7SG = 2.6 m 3. Do we have to prepare the test samples to the gross weight = 14.3 kg for the drop test. Or the drop height calculated above is already taken care of that? For the preparation for stack test, we always perform on empty boxes. What about for vibration test: water will be just ok for the test or also with exact gross weight as claimed? weight, assuming that the specific gravity & drop height are already defined. Also, could you give me a section in CFR 49 about to calculate the maximum gross I look forward to your response. You also can reach me al 408-734-9724. Sincerely, Jank Lansmont Corporation. Tramy L' 1287 Reamwood Avenue • Sunnyvale, California 94089 • Phone: (408) 734-9724 - Fax: (408) 734-9762 Lansmont Corporation • Western Technical Service Center IO 'd 29L6-18L 200#