Reactives Management Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAY 0 5 2010 1200 New Jersey Ave, SE Washington, D.C. 20590 Ms. Cherie Walton Reactives Management Corporation 1025 Executive Blvd., Suite 101 Chesapeake, VA 23320 Ref. No.: 05-0111R Dear Ms. Walton: This is a follow up to your April 28, 2005 letter requesting clarification regarding the general packaging requirements specified under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked if it is permissible for a specification combination package (a UN 4G fiberboard box with inner metal receptacles), which was tested for liquids, to be filled with a solid material as long as the gross mass marked on the packaging is not exceeded. This letter is a revision to our original response from June 17,2005. The HMR, at § 178.602, require each packaging to be closed in preparation for testing and tests to be carried out in the same manner as ifprepared for transportation, including inner packagings in the case of combination packagings. Therefore, a combination packaging design originally tested with inner packagings containing liquids may not be used to package solid materials, as a single package or otherwise, without further testing. I hope this information is helpful. Should you have any further questions, please contact this office. Sincerely, ~? Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office ofHazardous Materials Standards#

Page 2Message ~54- tff;/,..~th W!li'k.Page 1 of 1 ~ 11.:.1 . /?~t.f l,: (b) ~ M,..;...I,_IN_FO_C_NT_R_<P_H_M_SA_>_~_._______ .;....,1} N_",_t ...;:;.)lc.....;.../_k. fad<qgJ.fJ S .., From: reactives@earthlink.net fla.e j~4Je ~ Sent: Thursday, April 28, 200512:39 PM To: INFOCNTR <PHMSA> 05 - {JIll Subject: Information Center Comments/Questions Complete by Phone, Left VM to call HMIC 4/28/2005 KAL Below is the result of your feedba,~k fonn. It was submitted by Cherie Walton (reactives@earthlillknet) on Thursday, April 28, 2005 at 12:38:35. Email: reactives@earthlink.net Name: Cherie Walton Category: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 - 173.476)' Organization: Reactives Management Corp. Street: 1025 Executive Blvd., Suite 101 City: Chesapeake State: Virginia Zip Code: 23320 Phone: 757-436-1033 Fax: 757-548-2808 Comments: RE: Combination packaging. We have two sizes ofcombination packagings which are intended to hold liquids. Each combination packaging consists of inner metal cans (e.g. metal paint CiUlS) with locking rings. These are packed inside a 4GY. The markings on the outer 4Gs are as follows: 4GN9.61S104 USAI+AX4033 and 4GN38.51S/05 USAI+AZ4600 According to I 73.24a(b)(3), which addresses single or composite non-bulk packaging (not combination paekagings), solids may be packed in non-bulk packaging which has been tested for liquids. Can we use the above 4Gs (since they are marked with an "S") for solids as long as the gross mass in kilograms does not exceed the rated capacity ofthe packaging in liters? If so, are we required to pack the solids in the approved inner recepticles (paint cans)? Thanks for your help. 4/28/2005#