{"operation":"document","citation":"05-0279","title":"Regulatory Resources, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-12-13","effective_on":null,"summary":"05-0279 response to Regulatory Resources, Inc. concerning 173.465.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0279.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0279.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0279","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050279.pdf","body":"<<<PAGE 1>>>\n\n•\nof Transportation\nU.S. Department\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nHazardous Materials Safety\nPipeline and\nAdministration\nDEC 13 2005\nMr. Wade Winters\nRef. No. 0.5-0279\nRegulatory Resources, Inc.\n240 Joshua Road\nKennewick, WA 99338\nDear Mr. Winters:\nThis is in response to your November 1, 2005 letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you\nrequest clarification on the free drop test for Type 7A packages specified in § 173.465(c).\nIt is your understanding that center of gravity over impact point testing is not a required\ndrop test orientation for a Type 7A package, unless such an orientation would inpart\nmaximum damage to the package.\nYour understanding is correct. A Type 7A package, with its contents, must be capable of\nwithstanding a free drop test. The specimen must drop onto the target so as to suffer\nmaximum damage to the safety features being tested. The person conducting the free\ndrop test must determine the orientation that will produce the maximum damage.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\n173.465 (e)\n050279\n\n<<<PAGE 2>>>\n\n11/01/2005\n14:49 FAX\n509 628\n0972\nRegulatory Resources\nInc\n4002/003\nLear\n§173.465 (c)\nRegulatory\n240 Joshua Roa\nResources ne.\nTest\nVoice: 50-622-932\nfax: 509-628-0972\n\"The Source You Come Back To\".\n05.0279\nade@regulatoryresources.r\nww.regulatoryresources./\nNovember 1, 2005\nMs. Susan Gorsky\nOftice of Hazardous Materlals Standards\nPipellne and Hazardous Materials Safety Administration\nPHH-10\nU.S. Department of Transportation\n400 Seventh Street, SW\nWashington, DC\n20590\nDear Ms. Gorsky,\nDepartment of Transportation (DOT) Hazardous Materlals Regulations (HMRs) and the Environmental\nRegulatory Resources, Inc. (RRI) is a consulting and training company serving clients subject to the\nProtection Agency (EPA) solid and hazardous waste management regulation. One of our speclaity areas\ncovers the regulations for the safe transport of radioactive materlals. Various Class 7 packaging questions\nhave been ralsed in recent training classes and I'm seeking PHMSA's clarification on these. RRI Is seeking\nPHMSA concurrence as to the intent of 'maximum damage' concerning Type A package drop tests. We\ntest orlented with its center of grovity over the polnt of Impoct.\ndo not belleve that orientation for maximum damage is the same as requiring the package to be drop\nfissile solids must be dropped onto the target (e.g.. unyielding surface) so as to suffer the maximum\nThe 49 CFR 173.465(c), Type A packaging tests, Free drop test, states that the package containing non-\ndamage to the safety features being tested. Paragraph (c)(1) identifles the required free drop distance\nbased on package mass. This drop test requrement Is a test performed to simulated 'normal conditions\nof transportation'. The purpose of this test Is to reproduce the type of shock and damage that could be\nexperlenced if the package were to fall off a vehicle or loading dock. or if were to be dropped during\noccurrences.\nnormal handling. The test is not designed to simulate vehicle accident situations or accident type handling\nThe objective of the Type A package drop test is to inflict 'maximum damage' to evaluate the package\nfeatures such as structural components, containment systems, closures, and shielding configurations and\nproperties. To achieve maximum damage the package may require several drops in varying drop\nconfigurations, however, all possible drop orientations need not be considered providing that these drop\narlentations are not possible under normal conditions of transport. Naturally, these determinations must\nbe documented by the package designer and/or test engineer. As stated by the IAEA in TS-G-1.1, 1722.6:\n\"During the revision process leading to the 1996 edition of the Regulations, It was agreed that\nall possible drop test orientations need not be considered when conducting the drop test for\npackage to be dropped in certain orlentations, these orientations could be ignored in assessing\nnormal conditions of transport. Providing that it is not possible under 'normal' conditions for the\nthe worst damage. It was envisaged that this relaxation would only be allowed for large\njustification by the package designer.\"\ndimension and large aspect ratio packages. In addition this relief would require documented\n\n<<<PAGE 3>>>\n\n11/01/2005 14:49 FAX\n509 628 0972\nRegulatory\nResources Inc\n@003/003\n240 Joshua Road\nRegulatory Resources, inc\nVoice: 509-628-1020\nKennewick, WA 99338\nwww.regulatoryresources.net\nFax: 509-628-0972\nNovember 1, 2005\nMs. Susan Gorsky\nPage 2\nFor example, a package with a relatively large aspect ratlo (e.g., 4' wide x 4' high × 25' long) must be\ntested and evaluated based on its normal loading and handling configuration so that maximum damage\nis attained. Some users of Type A radioactive materials packagings require the manufacturer to test the\nnormal condition of transport as this orientation may not be within the scope of the design for the handling\npackage with Its center of gravity over the point of impact. The result of such test may be beyond any\nand transport configuration of the package. Clearly, such a drop configuration wil sublect secondary\nImpacts that far exceed any normal condition drop test requrement.\nRRI seeks PHMSA concurrence that center of gravity over impact point testing, based on the design of the\npackage as documented by the design and/or test engineers, Is not the same as the requirement to test\nthe package so that'maximum damage' Is Imparted to the package under normal conditions of transport.\norlentation unless such package orlentation would, in fact, impart maximum Impalment to the integrity\nFurthermore, we believe that center of gravity over impact point testing is not a required drop test\nof the package under normal condition of transport.\nThank you for your time in these matters. Please contact me if I can answer any questions.\nFor Regulatory Resources, Inc.,\nWade A. Winters, CET, CHMM\nPresident\nWAW/lom","truncated":false,"body_characters":6102}