Lawrence Livermore National Laboratory — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department AUG 27 2003 400 Seventh St., S.W. Special Programs Research and Washington, D.C. 20590 Administration Mr. Earl Thomas Reference No.: 03-0170 Lab Pack Operations Team Leader University of California Lawrence Livermore National Laboratory P. O. Box 808, L-668 Livermore, CA 94550 Dear Mr. Thomas: This responds to your letter requesting clarification on authorized packaging for poison inhalation hazard (PIH) materials under § 173.226(c)(2) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. We offer for transportation Division 6.1, PG I, Hazard Zone A materials in an inner packaging system consisting of three inner packagings; the HMR prescribe two inner packagings. We place a single one liter non-impact resistant glass receptacle in an impact- resistant packaging with compatible absorbent material. This in turn is placed into a leak- tight packaging, again with compatible absorbent material, that is packed within an outer 4G fiberboard box. The completed inner packaging system meets the performance standards at the PG I level in subpart M, part 178, of the HMR. Does this packaging meet the requirements in § 173.226(c)(2)? Al. The answer is yes. Even though you have an additional inner receptacle, your packaging meets the provisions in $173.226(c)(2). The capacity of each inner receptacle may not exceed 4 L (1 gallon). Both the inner packaging system and the outer packaging must meet the performance test requirements in subpart M, part 178, of the HMR. Q2. Under the provisions in §173.226(c)(2), may multiple inner impact-resistant glass receptacles containing Division 6.1, PG I, Hazard Zone A materials be packed into the leak-tight intermediate packaging? A2. Section 173.226(c)(2) authorizes multiple impact-resistant inner receptacles, provided the capacity of each inner receptacle does not exceed 4 L (1 gallon), and the total amount of 173,226 030170#

Page 2liquid contained in the outer packaging does not exceed 16 L (4 gallons). Additionally, the inner packaging system and the outer packaging must conform to the performance test requirements in subpart M, part 178, of the HMR. I hope this satisfies your inquiry. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Lawrence Livermore National Laboratory Environmental Protection Directorate Safety and June 24, 2003 Corbin Mr. Edward Mazzullo §173.226()E) Director, Office of Hazardous Material Standards/ Research and Special Programs Administration (DHM-10) Packaging 400 7" St SW Department of Transportation 03-0170 Washington D.C., 20590-0001 Subject: Inner Packaging Systems for Division 6.1 PGI, PIH, Zone A Materials Reference: 49 CFR 173.226 (c)(2) Dear Mr. Mazzullo: I would like to extend my sincere thanks to Mr. Cameron Satterthwaite for his interpretation of 49 twofold: CFR 173.226 (c)(2), as it applies to "impact-resistant" glass. The purpose of this correspondence is 1) To obtain written concurrence to the guidance that Mr. Satterthwaite provided us on December 18, 2002 and 2.) To pose an additional question (to your department) that is also related to 49 CFR 173.226 (c)(2). First, during our December 18 phone conversation, Mr. Satterthwaite concurred with me that placement of inner-glass containers (holding materials meeting the definition of division 6.1 PGI, Zone A inhalation-hazard [PIH]) into non-breakable intermediate containers meets the "impact- resistant glass" requirement, provided that the following conditions are met: • The intermediate container is compatible with the lading. • Movement of the inner-glass container is restricted within the intermediate packaging via a compatible absorbent medium or other appropriate dunnage. • The final inner packaging system conforms to the performance test requirements of 4 FR 178 Subpart M, at the Packaging Group I level. See Illustration / breakable containers) preserves the intent of the regulation and provides much needed relief t VI. Satterthwaite's interpretation (of conditionally allowing the use of intermediate non the regulated community. However, before implementing this guidance, we are requesting a expressed position. written response from the Office of Hazardous Materials Standards, reiterating the previously An Equal Opportunity Employer • University of California • P.O. Box 808, L-668, Livermore, California 94550 (925) 422-3343 - Fax (925) 424-2415#

Page 4identical liquid material, meeting the definition of 6.1 PGI, Zone A PIH, be packed into a single Second, given the three requirements itemized below, can multiple inner-receptacles, holding "leak-tight packaging of metal or plastic," or does 173.226 (c) (2) contain language prohibiting such an assembly? • No inner receptacle exceeds 4L in capacity. • The total amount of liquid contained in the outer packaging does not exceed 16L. • The specific package configuration is tested in accordance with 49 CFR 178 subpart M, at the Packaging Group I level. See Illustration E forward to your response with much anticipation. Again, we greatly appreciate the technical support that your department provides and look same phomas Earl Thomas Lawrence Livermore National Laboratory Lab Pack Operations Team Leader Illustration A Illustration B absorbent media Shaded area = UN 1H2/X9/S/03/USA/Z0101 UN 1H2/X9/S/03/USA/Z0101 Non-breakable intermediate container resistant glass Non-impact receptacle Impact-resistant UN 4G/X31/S/03/USA/Z0101 glass receptacles UN 4G/X31/S/03/USA/Z0101 Leak-tight inner packaging 4G Outer packaging cc: Kerry Cadwell, Storage and Disposal Group Leader Dennis Barrett, Packaging and Transportation Safety, Program Manager John Bowers, Waste Treatment Group Leader, Authorized Derivative Classifier Kathryn Rauhut, Laboratory Counsel, General Law Office#