{"operation":"document","citation":"07-0143","title":"PerkinElmer Optoelectronics — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-01-09","effective_on":null,"summary":"07-0143 response to PerkinElmer Optoelectronics concerning 173.115, 173.22, 173.306.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0143.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0143.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0143","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070143.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave . S E\nWash~ngton, DC 20590\nJanuary 9,2008\nMr. David Harmon\nPerkinElmer Optoelectronics\n44370 Christy Street\nFremont, CA 94538\nRef. No. 07-0143\nDear Mr. Harmon:\nThis responds to your email concerning the applicability of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 17 1-180) to certain arc lamps containing small amounts of\na Division 2.2 gas under pressure. Specifically, you ask if the lamps are subject to regulation\nunder the HMR.\nThe lamps are manufactured by Cermax and PerkinElmer to a specification you provide and\nare offered for transportation in the packaging configurations described in your letter. We\nagree that Cermax and PerkinElmer brand lamps containing less than 30 mL of gas are\ntransported in a quantity and form that will not pose an unreasonable risk to health, public\nsafety or property during transportation. Therefore, it is our determination that they are not\nsubject to the requirements of the HMR.\nHowever, it is our determination that the Cermax brand lamps containing between 68 mL and\n270 mL of xenon and charged to a pressure between 275 psig and 500 psig are most\nappropriately described using the shipping description \"UN 3363, Dangerous Goods in\nApparatus, Class 9.\" You may wish to consider using the limited quantity exceptions\nprovided in 5 173.306 for shipments of compressed gas. For international transportation, the\nlamps must be prepared for transportation in accordance with applicable international\nregulations.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nDirector\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nPage 1 of 3\nDrakeford, Carolyn <PHMSA>\nFrom: Gale, John <PHMSA> 07- 0 /\nSent: Friday, July 13, 2007 8:30 AM\nTo: Kelley, Shane <PHMSA>; INFOCNTR <PHMSA>; Drakeford, Carolyn <PHMSA>\nSubject: RE: Perkinelmer Arc lamps\nFrom: Harmon, David [mailto:David.Harmon@perkinelmer.com]\nSent: Mon 6/25/2007 7:08 PM\nTo: Kelley, Shane <PHMSA>\nCc: dgicc@aol.com\nSubject: Perkinelmer Arc lamps\nShane,\nAs we discussed on the telephone on June 2oth, 2007, 1 am writing to request your department to please issue an\nopinion and interpretation on the shipping of our products relative to \"Dangerous Goods\" classification. I have\nincluded as much information as possible to help you make your determination. Thanks in advance for your\nconsideration and attention in this manner.\nCompany Information:\nWe are an Optoelectronics company headquartered in Fremont California and we produce various types of arc\nlamps which contain Xenon, Krypton or a mix of these two gases. We ship these lamps from 2 principle factories;\nFremont, CA and Singapore and we ship them both domestically and internationally from those 2 locations. They\nalso are shipped to both end customers and distributors includirlg our site in Wlesbaden Germany who is a\ndistributor for the EU.\nGeneral ~roduct use description:\nThese lamps are used in several ways in several applications. The majority of these lamps are branded as\n\"Cermax\" lamps. The entertainment industry uses these lamps for high end movie projectors (such as IMAX\nTheater) or high end projection televisions as well as normal theater projection equipment and lighting. The\nmedical lighting industry uses these lamps for endoscope machines, for general operating room lighting\nconditions and other related types of equipment. They are used in some military applications for guidance or\ncountermeasures applications given by light. Others lamps which are carried under the PerkinElmer brand are\nused as \"flash lamps\" for laser and industrial applications; these are small quartz tubes that are utilized to create a\nbright flash of lights which is used to create laser lighting or beacons.\nGeneral product contents:\nThe majority of our lamps are filled with Xenon gas; some lamps are filled with Krypton or a mix of\nKryptonlxenon. These gases by themselves are neither flammable nor explosive meaning that they are inert\ngases. The vessel where the gas is contained is produced with a combination of safire, ceramic and steel. These\nmaterials are then joined by a comb~nation of brazing and/or TIG welding.\nShipping details:\nThe lamps are packed in open cell packing foam, which fits each lamp model to its unique form and is\napproximately 2\" to 4\" thick per side, depending on the lamp. This foam is then surrounded by an initial single\nwall card board box which is rated at a 200 Ibs per square inch bursting strength, then multiple boxes of this\nnature are packed together into a larger double wall box which is rated at 275 Ibs per spare inch bursting strength\nas well as containing Styrofoam packing peanuts. Though there are a few variants depending on the lamp and/or\ncustomer but this is the typical shipping method. We regularly ship these lamps via air andlground both\ndomestically and internationally through various carriers.\nProduct Abuse Testina:\nIn 2005, we carried out some testing on our lamps used in the entertainment industry for one of our customers\nregarding the strength of the product itself. I have attached a copy of this report in case it may be helpful for you.\nThis is the PDF file called Quanta failure reporting. It details the force required to burst the lamp itself both from\n\n<<<PAGE 3>>>\n\nPage 2 of 3\nthe perspective of force applied, dropping, shock and vibration testing. The result is that it takes a pretty\nsignificant load to break the lamp housing and when doing so the internal elements are contained (except of\ncourse the gas).\nShippina confiqurations:\nIn the attached powerpoint file, you can see pictures of the lamps which are described above. In the first slide (fig\n#A) the top left corner pictures, are of a \"bare\" cermax lamp. This is the base configuration for most of the Xenon\narc lamps. We ship the lamps in this configuration most often but also ship them inside of a module and inside of\na system. The bare lamp is also placed into a module (which can be seen in fig. #2) and into an endoscopy\nsystem (slide #2, fig. #3). The next slide then shows picture examples of the PerkinElmer brand flash lamps.\nThese lamps are filled either with Xenon, Krypton or a mix of those two gases. These can be seen in slide #2, fig.\n#4.\nCurrent classifications:\nCurrently we are shipping lamps under two different dangerous goods classifications; 1) Dangerous Goods in\nApparatus, UN3363, Haz Class 9 and 2) Dangerous Goods in Excepted Quantities, UN2036, xenon, Haz Class\n2.2. The reason for the difference in classification is that some of our lamps carry less than 30ml of gas and\nothers carry larger quantities of gas at different pressures. As you probably already know, we arrived at these\nclassifications types by working with Candy Cook from DGI.\nQuantities and pressures:\nThough we ship a number of different models of these lamps in which the fill amount and pressure may vary, I\nhave attempted to group them below as minimums and maximums for simplicity. These groupings are listed\nbelow and are given by a population of models which fit into the maxlmin listed. .\nCermax brand lamps -Xenon filled - currently UN2036\nMinimum pressure 30 Ibs per square inch Maximum pressure 415 Ibs per square inch Minimum gas amount inside the lamp 8ml\nMaximum gas amount inside the lamp 26ml\nCermax brand lamps - Xenon filled - currentlv UN3363\nI Minimum pressure 275 Ibs per square inch lblaximum pressure 500 Ibs per square inch Minimum gas amount inside the lamp 68ml\nMaximum gas amount inside the lamp 270ml\nPerkinElmer brand lamps - Krypton filled - currently UN3363\nMinimum pressure 42 Ibs per square inch Minimum gas amount inside the lamp 1 ml\nMaximum pressure 70 Ibs per square inch Maximum gas amount inside the lamp 8ml\nPerkinElmer brand lamps - Xenon filled - currently UN3363\nMinimum pressure 44 Ibs per square inch Minimum gas amount inside the lamp .4 ml\nMaximum pressure 58 Ibs per square inch Maximum gas amount inside the lamp 2 ml\nPerkinElmer brand lamps - Krypton and Xenon filled - currentlv UN3363\nMinimum pressure 41 Ibs per square inch Minimum gas amount inside the lamp .4 ml\nMaximum pressure 141 Ibs per square inch Maximum gas amount inside the lamp 8 ml\nI have tried to provide you with sufficient information to make a conclusive determination. It is our belief that\nthese lamps should not pose a hazard to transportation and therefore should not be classified as dangerous\ngoods. If the lamps were to somehow be broken during transportation, the gas would escape from the housing\nand all parts would be contained within the lamp housing and or the box. As the gas is an inert gas, the risk or\ndanger to anyone within close proximity would be none or almost none. While we wait for your determination we\nwill continue to ship these lamps under the two DG classifications currently designated.\nWe very much appreciate any opinion you can render for us and look forward to your reply,\nRegards,\nDave\nDave Harmon\n\n<<<PAGE 4>>>\n\nI\nc Director of Quality, EH&S and Continuous Improvement\nPerkinElmer Optoelectronics\n44370 Christy Street\nFremont, California - 94538\nPhone: 5 10-979-6862\nMobile: 5 10-364-7360\nFax: 5 10-687-1 152\ndavid.hamon(~pcrkineI!ner.com\nPage 3 of 3","truncated":false,"body_characters":9294}