Department of the Army — Hazardous Materials Safety Interpretation

Page 1I.S. Departmen f Transportatio Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration SEP 1 1 2006 Physical Scientist Ms. Lauren Oleksyk Reference No.: 06-0137 epartment of the Arm 'ombat Feeding Directorat Kansas Street Natick, MA 01760-5018 Dear Ms. Oleksyk: This responds to your letter concerning transportation of a heater that is a component in a Unitized Group Ration - Express (UGR-E) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask how packages containing UGR-Es must be marked and labelled if they are determined to be subject to the HMR. You describe the UGR-E as a self-contained, self-heating module that provides a complete meal for up to 18 personnel, with heaters and trays of food packaged together in an intermediate fiberboard box. A module has four heaters, each containing 85 grams of magnesium alloy powder, for a total of 340 grams per module. In the Type I version, the four heaters are hermetically sealed within a tri-laminate pouch and placed on top of the inner heating module case. In the Type II version, each hermetically sealed heater is mL solution of 1.5% salt in water which is dispensed from a pouch assembled within each placed in the bottom of the heating tray. The individual heaters are activated with a 300 heating tray. The outer packaging of each module is a fiberboard box with the completed four heaters generate approximately 11 cubic feet of hydrogen gas. Your correspondence package weighing approximately 42 pounds. During the 45-minute heating process, the included illustrations and assembly instructions for both types of UGR-E, as well as a Material Safety Data Sheet; you also provided a prototype of each module type sans heaters, and one Type I heater pouch containing four heaters. Based on the information you provided, the most appropriate shipping description for the L'GR-E is "Magnesium alloys, powder, 4.3, UN 1418, PG II." The HMR do not authorize any exceptions in column (8A) for this entry; therefore, the UGR-Es are fully regulated. When offered for transportation in commerce, in addition to meeting the specification § 172.301 (proper shipping name, identification number, etc.) and labeled with the packaging requirements in § 173.212, non-bulk packages must be marked as specified in DANGEROUS WHEN WET label in accordance with Subpart E of 49 CFR Part 172. For transportation by aircraft, packages prepared in accordance with the International Civil Aviation Organization's (ICAO) Technical Instructions must also be marked with the name and address of the shipper and consignee. 171.2 172.30/ 060137 192.101#

Page 2You may wish to seek relief from some of the requirements detailed in the previous paragraph under the terms of a special permit by contacting the Pipeline and Hazardous Materials Safety Administration's Office of Hazardous Materials Special Permits and Approvals (OHMEA). Special permits are granted on a case-by-case basis. Procedures for reached at (202) 366-4512. applying for a special permit are set forth in 49 CFR 107.105. The OHMEA may be I trust this satisfies your request. Sincerely, Hathe zi intatel Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Corbin DEPARTMENT OF THE ARMY $171.2 NATICK MA 01760-5018 KANSAS STREET $172.101 REPLY TO ATTENTION OF : AMSRD-NSC-CF-| 12 May 200 06-0137 U.S. Department of Transportation Pipeline Hazardous Material Safety Administration 400 7* Street Southwest Office of Hazardous Material Safety Washington, DC 20590 06 MAY 24 DOT/RSPA / OHMS (HMR) for Proposed Military Ration, Unitized Group Ration-Express. 1. Subject: Request for U.S. DOT Interpretation of Hazardous Materials Regulations 3 2. References: 14 a. U.S. DOT letter, July 7, 1992: Flameless Ration Heater (FRH) for Meal, Ready-to- . U.S. DOT-E 10897, October 26, 1992: Exemption of bulk packed FRHs fron Eat considered not subject to Hazardous Materials Regulations (HMR). (Encl 1) HMR marking and labeling. (Encl 2) regulated when packaged within the Meal, Ready-to-Eat (MRE) standard combat ration. However, the UGR-E heater is a larger heater, does not contain salt in the powder blend, requested. 4. NSC is in the process of procuring 220 UGR-E rations for shipment to Iraq in May CR 172.301 and 172.400 and previous decisions regarding the FRH, we request your opinion on whether or not UGR-E Type I and Type II packages are subject to HMR. If the UGR-E is found to be subject to HMR, please specify what HM markings and labels are required for both domestic and international shipment via ground or air.#

Page 4AMSRD-NSC-CF-I 5. Questions or comments may be directed to Lauren Oleksyk, Tel: (508) 233-4555 or email lauren.oleksyk@natick.army.mil, or Peter Lavigne, Tel: (508) 233-4939 or email peter.lavigne@natick.army.mil. Thank you for your attention to the matter. LAUREN OLEKSYK Combat Feeding Directorate Physical Scientist Natick Soldier Center Enclosures: 1. U.S. DOT letter, July 7, 1992 2. U.S. DOT-E 10897 3. Description of proposed Unitized Group Ration - Express (UGR-E), Type 1 and 4. Material Safety Data Sheet for UGR-E heater. Type II. 2#