Defense Logistics Agency — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and JUL 18 2003 Administration Ms. Janet Cravener Ref No.: 03-0163 Chief, Distribution Operations Defense Logistics Agency 2001 Mission Drive New Cumberland, PA. 17070-5000 Dear Ms. Cravener: This responds to your June 26, 2003 letter and subsequent conversation with Mr. Darral Relerford concerning the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for performance-oriented packagings. Specifically, you ask about the appropriate packaging for a shipment by air of ethylene oxide and propylene oxide mixtures, with not more than 30 percent ethylene oxide, Class 3, UN 2983, PG I. You propose to package your material in a combination package that consists of 5-liter plastic bottles contained within a 1A2 steel drum with a 4-mil polyethylene liner. You note that the inner packaging does not meet the hydrostatic pressure requirements for air shipment, as required by § 173.27(c)(ii) of the HMR. For transportation by aircraft, the outer packaging of a combination packaging containing inner packages of a PG I liquid product is not required to meet the 250 kPa (36 psig) test pressure prescribed in § 173.27(c)(3)(ii). Section 173.27(c)(3)(ii) only applies to single and composite packages intended to contain liquids. Combination packages are not subject to the hydrostatic pressure test and marking requirements of §§ 178.605 and 178.503(a)(5) respectively. Section 173.27(c)(2) requires that packages for which retention of liquid is a basic function must be capable of withstanding without leakage an internal pressure based on the vapor pressure of the material to be transported. Section 173.27(c)(3)(i) allows inner packages that are not capable of meeting the pressure requirement to be placed in a supplemental packaging that meets the pressure requirements. Note that, although § 171.8 of the HMR includes separate definitions for "inner packaging" and "inner receptacle" the terms are used interchangeably throughout the HMR and are not interpreted to be different items. I hope this information is helpful. Please contact us if you require additional assistance Sincerely, Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 173.27 030163#

Page 2Relerford DEFENSE LOGISTICS AGENCY DEFENSE DISTRIBUTION CENTER $173.27 NEW CUMBERLAND, PA 17070-5000 2001 MISSION DRIVE Packaging IN REPLY REFER TO 03-0163 DDC-J-3/J-4-O JUN 2 6 2003 STANDARDS MEMORANDUM FOR DOT, RSPA, OFFICE OF HAZARDOUS MATERIALS SUBJECT: Request for Interpretation, 49 CFR 173.27 appropriate for the contents below. Drum markings: UN 1A2 / X 1.5 / 95 / 03 / USA / ** Request assistance to determine if the following open head drum configuration is (** = Manufacturer Authorized Symbol). If this drum is not appropriate, please state Hazardous Class: 3, UN Number: UN2983 PSN: Ethylene oxide and propylene oxide mixtures, with not more than 30 percent oxide PG: I Relative Density 0.87 Physical State of Material: Liquid Vapor Pressure at 50 or 55 degrees centigrade: Unknown Quantity: 30 Liters Inner packagings: Plastic Bottles, 5 liters each. Total Quantity: 6 bottles Note: Inner Packaging does not meet Hydrostatic Pressure Requirements for air shipment Intermediate Packaging: 4-Mil polyethylene liner. Absorbent: Vermiculite Vuter Packaging: Steel Drum, 1A2 Packaging Paragraph: 173.201 POC is Ms. Linda McCarthy, Commercial telephone (717) 770-8238. Your assistance is appreciated. Dout Awere IANET CRAVENER Chief, Distribution Operations Federal Recycling Program 2 Printed on Recycled Paper#