Hazmatpac Certified Packaging — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety DEC 1 2005 Mr. Donald H. Hausmann Ref. No. 05-0102 Hazmatpac Certified Packaging 5301 Polk St., Bldg. 18 Houston, TX 77023 Dear Mr. Hausmann: This is in response to your letter requesting clarification of the Hazardous Materials Regulatiors (HMR; 49 CFR Parts 171-180) regarding the use of used vermiculite as an absorbent and cushioning material in UN specification packagings. Specifically, you asked whether the HMR authorizes the reuse of vermiculite that was used in a previous shipment. You also asked whether a grade of vermiculite that varies (such as smaller or larger granules) from the grade used when the packaging was tested may be used when shipping hazardous materials. Previously used vermiculite may be used in subsequent packagings provided it has not been compromised and can perform the securing, cushioning and absorbent functions required by §§ 173.24, 173.24a, 173.27, and 178.601, as applicable. With respect to whether a different grade of vermiculite may be used if the packaging was tested with a smaller or larger grade of vermiculite, the packaging must meet the standard to which it is certified and the material must be of the same type or design as used in the tested design type. Without specific test data indicating the two grades of vermiculite have similar cushioning properties, it is not possible for us to make a determination that your samples of vermiculite are of the same type and may be interchanged without further testing. I hope this information is helpful. Please contact this office if you have additional questions. Sincerely, Hothe z Mitchell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 050102#

Page 2HAZMATPAC® Webb CERTIFIED PACKAGING $178.601()(3) (V) 5301 POLK STREET, BLDG. 18 HOUSTON, TEXAS 77023 www.HAZMATPAC.com (3) (iv) 713.923.2222 1.800.923.9123 April 14, 2005 Testing FAX 713.923.1111 05-0102 Office of Hazardous Material Standards Mr. Edward T. Mazzullo Research and Special Programs Administration Department of Transportation 400 Seventh St. SW, Room 8321 Washington, DC 20590-0001 Dear Mr. Mazzullo, I am requesting a written response to this letter. I have two questions pertaining to the use of vermiculite as an absorbent and cushioning material for compliance of the United Nations testing. My first question pertains to the reuse of vermiculite from previously shipped packages. Is it proper to reuse vermiculite from a previously shipped container? Several test reports I have inspected did not stipulate new or used vermiculite. To comply with the United Nations testing, would a shipper be required to use only new or virgin vermiculite? Vermiculite is a good absorbent but when crushed it does not spring back. I have enclosed samples of vermiculite for your review. The second question deals with the different grades of vermiculite. If a package is tested grade? Is there an instance when a package is tested with a smaller grade vermiculite be with a certain grade vermiculite can the grade of vermiculite be substituted for another substituted with a larger grade or a package tested with a large grade vermiculite be substituted with a smaller grade. Thank you for your time and consideration I this matter. Respectfully. Donald H. Hausmann Enclosure#

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