{"operation":"document","citation":"08-0139","title":"URS Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-06-20","effective_on":null,"summary":"08-0139 response to URS Corporation concerning 171.8, 173.306.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0139.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0139.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0139","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080139.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJUN 2 0 2008\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMs. Erin N. Jarman\nEnvironmental Scientist\nURS Corporation\n1600 Perimeter Park Drive\nMorrisville, NC 27560\nRef. No. 08-0139\nDear Ms. Jarrnan:\nThis is in response to your April 28,2008 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171 -1 80) applicable to the packaging requirements\nfor transporting non-pressurized gas samples.\nIn your letter, you ask whether shpping gas samples in \"Tedlar\" bags placed in a one-quart\nmetal can (similar to a paint can) with a hction lid sealed with plastic-ring seals is permissible\nunder the HMR. You also provide a copy of the product documentation for the friction lid metal\ncans indicating a hyrdrostatic test rating of 100kPa.\nSection 173.306(a)(4)(iii) requires non-pressurized gases, flammable to be packed in\nhermetically sealed glass or metal inner packagings of not more than 5 L (1.3 gallons) and\noverpacked in a strong outer packaging. Section 17 1.8 defines \"hermetically sealed\" as closed\nby fusion, gasketing, crimping, or equivalent means, so that no gas or vapor can enter or escape.\nIt is the opinion of this Office that the metal can with a friction lid sealed with plastic-ring seals\ndescribed in your letter meets the definition of \"hermetically sealed,\" and therefore can be used\nas an inner packaging as specified in § 173.306(a)(4)(iii).\nI hope this information is helpful.\nSincerely, J@\nhief, Standards Development\nof Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nApril 28, 2008\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\nU.S. DOTIPHMSA (PHH-10)\n1200 New Jersey Avenue, SE East Building, 2nd Floor\nWashington, DC 20590\nDear Mr. Mamllo:\nI am writing to you with regards to clarification on the proper packaging for the purpose of\ntransporting non-pressurized, flammable gas samples. The gas samples are collected using TedlarB\nbags which vary in size. A few T e d l d bags are then typically placed into a I -quart metal can\n(similar to a paint can) that closes using a tightly sealing friction lid. The friction lid is then locked\ninto place using a heavy duty plastic-ring seal. FinaIly, the sealed can containing the gas samples is\nfurther overpacked in a strong outer packaging such as a fiberboard box. Once the heavy duty\nplastic-ring has been placed around the head of the metal can, it is very difficult to remove and\ntherefore appears as though it provides adequate protection against gas releases.\nFor purposes of Section 173.306(a)(4)(iii), there has been some debate within industry as to whether\nor not this type of friction lid metal can, paired up with a plastic-ring seal would satisfy the\nrequirement to place non-pressurized gases, flammable into \"hermetically sealed\" glass or metal\ninner packagings? In an interpretation issued by RSPA (PHMSA) on March 15,2000 (Billings to\nGilbert, Ref. No. 99-0270) the letter stopped short of giving final DOT approval for this type of\npackaging and whether it would indeed meet the definition of \"hermetically sealed\" found in 49\nCFR 6171.8. due to the fact that no product testing information had been provided to your office by\nMr. Gilbert.\nThis type of friction lid metal can, with heavy duty plastic-ring seal is manufactured by numerous\npackaging manufacturers throughout the U.S. and abroad and is widely available through packaging\nsuppliers. One example in particular is available through HAZMATPAC (Stock numbers C-674#\nand C-684#). I am providing for your review a copy of the product documentation as published by\nHAZMATPAC, just one of the many suppliers of this type of can and plastic ring-seal.\n\n<<<PAGE 3>>>\n\nprovide regarding whether this type of widely used packaging would meet the definition of\n\"hermetically sealed\" and would therefore be acceptable for the transportation of non-pressurized,\nflammable gas samples as specified in Section 173.306(a)(4)(iii).\nThank you in advance for your assistance. 1 look forward to your response.\nSincerely,\nErin N. Jarman\nEnvironmental Scientist\nLlRS Corporation\n1600 Perimeter Park Drive\nMorrisville, NC 27560\nTel: 9 19-46 1- 1478\nFax: 919-461-1371\nErin-Jarman@urscorp.com","truncated":false,"body_characters":4287}