{"operation":"document","citation":"06-0155","title":"Transportation Systems Solutions — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-09-15","effective_on":null,"summary":"06-0155 response to Transportation Systems Solutions concerning 173.127.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0155.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0155.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0155","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060155.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nSEP 15 2006\nAdministration\nMr. Peter Olsen\nTransportation Systems Solutions\nRef. No. 06-0155\n318 Hampshire Lane\nCrystal Lake, Illinois 60014\nDear Mr. Olsen:\nThis is in response to your June 27, 2006 letter requesting clarification of the Hazardous\nHazard Division 5.1 Oxidizers. Your questions are paraphrased and addressed as follows:\nMaterials Regulations (HMR; 49 CFR Parts 100-180) applicable to testing criteria for\nQ1.\nIs a material that does not meet the definition of an \"Oxidizer\" as specified under\n§ 173.127 of the HMR when it is transported in a solid tablet form required by the\nto conduct the oxidizer test?\nUnited Nations (UN) Manual for Test and Criteria to be ground to a powder form\nAl.\nAs specified in § 173.127 of the HMR, a solid material is classed as a Division 5.1\nmaterial (Oxidizer) if, when tested in accordance with the UN Manual o: Tests and\npotassium bromate/cellulose mixture. The UN Manual of Tests and Criteria\nCriteria, its mean burning time is less than or equal to the burning time cf a 3:7\nspecifies that tests are conducted on the substance to be evaluated mixed with dry\nfibrous cellulose in mixing ratios of 1:1 and 4:1, by mass, of sample to cellulose.\nThe UN Manual of Tests and Criteria also specifies that a substance, in the form in\nin diameter. If that powder constitutes more than 10% (mass) of the total, or if the\nwhich it will be transported, should be inspected for any particles less than 500 um\nsubstance is friable, then the whole of the test sample should be ground to a powder\nbefore testing to allow for a reduction in particle size during handling and transport.\nIn addition, the UN Manual for Tests and Criteria specifies that, as the particle size\nfor a solid substance to increase the burning rate or burning intensity of a\nhas a significant effect on the result of the test performed to determine the potential\ncombustible material, the particle size of the substance should be stated in the test\nreport.\nQ2.\nIf the material that has been ground to a powder form meets the definition of an\n\"Oxidizer,\" does the UN Manual for Tests and Criteria allow for a specific\npercentage of the powder to be generated from the tablet form?\nA2.\nSee response above.\n173.127\n060155\n\n<<<PAGE 2>>>\n\nQ3.\nIs there a grain size limit for the powder of the above material generated before the\ntablets would be considered an \"Oxidizer\" under § 173.127?\nA3.\nSee response above.\nI trust this satisfies your inquiry.\nSincerely,\n/ Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nFoster\n$173.127 (g()\nDetinition\nTransportation Systems Solutions\n06-0154\n318 Hampshire Lane - 0/55\nCrystal Lake\n815-479-0897\nIllinois, 60014\nU.S Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n400 7° St S.W\nOffice of Hazardous Materials Safety\nWashington, DC 20590-0001\nDear Sir/Madam,\nTransportation Systems Solutions (TSS) respectfully seeks an interpretation as\ne solid oxidizer in question is in a solid tablet form for transportation purpose\nnd when in this solid tablet form it does not meet the definition of an oxidizer a\ndefined in 49 CFR 172.127 is it required that this tablet be ground to a powder\nform to conduct the oxidizer test? Given that if the solid tablet is ground to a •\npowder that it does meet the definition for an oxidizer TSS respectfully asks does\nhe UN Manual for Test and Criteria allow for a certain percentage of powder to\nfor the powder generated before the tablets would have to be considered an\noxidizer by definition?\npackaged in an impervious plastic liner in a strong outer packaging such that any\nThe solid tablets in question, that do not meet the definition of an oxidizer, are\npowder generated during transport would not be released.\nI thank you for your assistance in this matter and look forward to your response.","truncated":false,"body_characters":3946}