{"operation":"document","citation":"05-0132","title":"nanoCoolers — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-07-19","effective_on":null,"summary":"05-0132 response to nanoCoolers concerning 172.101, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0132.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0132.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0132","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050132.pdf","body":"<<<PAGE 1>>>\n\nof Transportatior\nJ.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nHazardous Materials Safety\nPipeline and\nAdministration\nJUL 19 2005\nMr. Craig Johnston\nReference No.: 05-0132\nnano Coolers\n5307 Industrial Oaks Boulevard\nAustin, TX 78735-8821\nDear Mr. Johnston:\nThis responds to your letter concerning the applicability of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) to your company's product, a thermal transport\nsystem. You describe the thermal transport system as being comprised of nickel and PVC\nbased tubing, a plastic pump, and a nickel/copper block. The block allows heat transport\nmaterial to flow through the block and pick up heat from a source component. All of the parts\nwithin the system are non-reactive with the heat transport material. The thermal transport\nmaterial flows through a closed cooling loop that contains a source heat exchanger, an\nambient heat exchanger, and piping to interconnect them. The thermal transport system\ncontains not more than 10 mL of thermal transport material consisting of the following\nelements by weight: 50-76% Gallium, 0-25% Indium, 0-15% Tin, 0-4% each Zinc, Silver and\nBismuth, and less than 1% Copper. The entire system is sealed and the design is tested to\nensure no release of fluid. You also submitted drawings of the system and test data.\nOf the identified materials, only gallium is regulated as a hazardous material. Section\n173.162(c) excepts manufactured articles and apparatuses, each containing not more than 100\nexceed 1 g (0.35 oz.) from the HMR. Your company's thermal transport system exceeds the\nmg (0.035 oz.) of gallium and packaged so that the quantity of gallium per package does not\nquantity of hazardous material allowed by § 173.162(c) and, therefore, is subject to the HMR.\nYou may wish to seek authorization to transport your company's thermal transport system\nunder the terms of an exemption by contacting the Pipeline and Hazardous Materials Safety\nAdministration's Office of Hazardous Materials Exemptions and Approvals (OHMEA).\nEnder the MR. Proced ones Cosa-by ease bain exempion are set forth in 49 CER 10705.\nThe OHMEA may be reached at (202) 366-4512.\nI trust this satisfies your inquiry.\nSincerely,\nthill, z mithell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nUnmondone Materials Standards\n172.101 (P)\n173.22\n050132\n\n<<<PAGE 2>>>\n\nnanoCoolers\nMay 13, 2005\nCorbin\nMr. Edward Mazzullo\nDirector of Hazardous Materials Standards\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n$172.101 (P)\n400 7* Street, SW\n$173-22\nWashington, DC 20590\nApplicability\nDear Mr. Mazzullo:\n85-0132\nRequest for Interpretation on Thermal Transport System\nJuly 22, 2003 and 26 April, 2005 between representatives of nanoCoolers, Inc. and Dr. Charles\nPursuant to the meetings held at RSPA's office in Washington, DC on May 13, 2003,\nKe and Stan Staniszewski, I am writing to request a written determination that nanoCoolers'\ninnovative thermal transport system that contains a small amount of hazardous material is not\nsubject to regulation in transportation under the U.S. Hazardous Materials Regulations (HMR)\nsince in the quantity and form described herein it does not present a hazard to life or property in\ntransportation. (See 49 U.S.C. § 5103(a).)\nA.\nIntroduction\nThis request pertains to (i) the specific thermal management system tested and\nset forth in this document. (See Exhibit 2 and 3) It will be used in applications ranging from\npersonal computers to servers to consumer electronics to address the ongoing problems\nwill be capable of meeting the tests described in Exhibit 2 and will not contain more than 10ml of\nassociated with the heat generated by integrated circuits and other heat sources. The design\nthe thermal transport material.\nThe thermal transport material currently used is an alloy\ncomprised of several elements. The table bellows shows the percentage range of each element\nin the alloy.\nElement\nGa\nRange (wt.pct.)\n50 to 76\nIn\nSn\nO to 15\n0 to 25\nZn\n0 to 4\nAg\n0 to 4\nB\n0 to 4\nCu\n<1.0\nBased on the substantial amount of analytical and testing data contained herein, it is our belief\nthat the thermal transport systems, with a very limited amount of the hazardous material, does\nnot pose an unreasonable risk to health or safety under 49 U.S.C. Section 5103(a) and thus is\nnot subject to regulation.\nBackground\n\n<<<PAGE 3>>>\n\ni nanoCoolers\nnanoCoolers' Thermal Transport System Design\non the final system in which they will be installed. The current system is approximately 133.0\nThermal management systems can vary in physical dimensions and weight, depending\nmm × 125.2 mm × 20 mm [5.23\" x 4.9\" × 0.78\"]. However future systems could have slightly\ndifferent physical designs. Each current system currently has approximately 3.5ml of thermal\ntransport material. nanoCoolers anticipates future systems could have a maximum of 10ml of\nand vibration tests as described in Exhibit 2.\nmaterial. Of note, all of the systems are sealed to withstand severe thermal, shock, pressure,\nbased tubing, a plastic pump, and a nickel/copper block. The block is formed to allow the heat\nStructurally, nanoCoolers thermal transport systems are comprised of nickel and PVC\ntransport material to flow through the block and pick up a heat from a source component.\nWithin the system, all of the parts are non-reactive with the heat transport material. The cooling\nloop consists of thermal transport material flowing in a closed loop, containing a source heat\nexchanger, an ambient heat exchanger, and piping that interconnects them.\nelectromagnetic pump and associated power supply are used to move the fluid throughout the\nAn\nsystem. The electromagnetic pump has no moving parts. The fluid moves by the Lorenz force.\nThe entire system is sealed and the design is tested to ensure no release of fluid.\nIn light of the design of nanoCoolers' thermal transport systems, the risk of the thermal\ncompletely unrelated to the integrity of the thermal transport system, is highly remote. The\ntransport material being released during usage or transport, absent a catastrophic event\nsystem. In the case of a catastrophic event the thermal transport system would be contained\nlimited quantity of hazardous material at issue would not separate from the thermal transport\nwithin the laptop computer or other electrical device housing the unit.\nIndependent Testing Confirms nanoCoolers Thermal Transport Systems Do Not Present\nan Undo Risk\nnanoCoolers contracted with Professional Testing, Inc. in Austin, Texas to conduct\nvarious standardized tests on the thermal transport system to ensure the product can withstand\nincidents normally found in transport. These include thermal, mechanical shock, pressure, and\nvibration tests. (See Exhibit 2) The results of PTI's tests demonstrate that under conditions\ntransport material will not be released. (See Exhibit 3 and 4)\ngreatly exceeding what normally can be expected during transport, the small amount of heat\nThe results also support\nnanoCoolers' belief that the thermal transport system does not pose a material risk in transport,\nbarring a catastrophic event.\ncomplies with all the applicable requirements.\nUL has recently completed its investigation of our customers product has determined it\nUL has filed the certification under E251599\nProject 05CA05208 for the USL/CNL- MODEL A+1850 SERVER (See Exhibit 3). These results\nalso support nanoCoolers' belief that the thermal transport system does not pose a material\nsafety risk in transport.\nC.\nRecent U.S. DOT Interpretation Letters\nnanoCoolers, along with CapAnalysis Group in Washington, DC and Wiley Rein and\nFielding in Washington DC, has reviewed the hazardous materials laws and regulations to\ndetermine the appropriate shipping requirements for the particular alloy we are using as a heat\n\n<<<PAGE 4>>>\n\nnanoCoolers\ntransfer material. Thermal transport systems are not listed in the hazardous materials table in\n49 CFR Section172.101. The thermal transport alloys we are using as heat transport material\nwithin the system also are not listed.\nDOT recently issued written interpretations concluding\nthermal transport systems are not hazardous in the applications for which they are intended.\nthat products analogous to\n(See Exhibit 5-15) Contained within Exhibits 5-15 are samples of products containing small\namounts of hazardous material ranging from toxic gases to flammable solids and corrosives.\nCorrosives have a wide range of definitions. These include materials that cause full thickness\ndestruction of intact skin tissue within an observation period of up to 60 minutes starting after\nof intact skin tissue but exhibit a corrosion rate on steel or aluminum surfaces exceeding 6.25\nthe exposure time of three minutes or less to those that do not cause full thickness destruction\nmm (0.25 inch) a year at a test temperature of 55 deg. C (130 deg. F). The corrosive material in\nour product is not destructive to skin tissue at all but is corrosive to aluminum or steel at a rate\nexceeding 6.25mm (> (>0.25 inches) per year.\nThe products in Exhibit 5-15 show that the\nquantity and form of packaging can remove an article from the hazardous materials regulations.\nis consistent with DOT's previous position on certain products containing small amounts of\nWithout reviewing each issuance in Exhibit 5-15, the thermal transport system described herein\nhazardous materials that are not be subject to the U.S. HMR.\nD.\nConclusion\nWe believe that the combination of a strong, robust structure, small product size,\nabsence of internal chemical reaction, and limited hazardous content (no more than 10 ml of\nheat transfer material) supports our conclusion that the thermal transport system presents no\nmaterial risk to health, safety or property in the intended application and thus is not subject to\nthe U.S. HMR. nanoCoolers respectively requests DOT's concurrence that the thermal\ntransport system described herein is not subject to the U.S. HMR.\nor if you require any additional information.\nPlease do not hesitate to contact me if you have any questions concerning this request,\nBest Regards,\nCraig Johpoion","truncated":false,"body_characters":10178}