Department of the Army, USAMC LOGSA Packaging Storage and Containerization Center — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration AUG 1 8 2P38 1200 New Jersey Ave. S E Wash~nqton DC 20590 Ms. Charlotte A Lent Chief, USAMC LOGSA Packaging Storage and Containerization Center 11 Hap Boulevard Tobyhanna, PA 18466-5097 Ref. No.: 08-0 1 84 Dear Ms. Lent This is in response to your July 10,2008 letter regarding non-bulk performance-oriented package testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically, you ask if the HMR restrict test substances for non-bulk packages designed to contain a liquid hazardous material to liquids having the same or higher)specific gravity than water and prohibit the substitution of solid materials as a replacement te:st product for liquids. According to 5 178.602(c), it is permissible to use additives, such as bags of lead shot, to achieve the requisite total package mass so long as they are placed so that the test results are not affected. You suggest that bags of lead shot cannot be placed in a way that will not affect drop test results because load distribution and shock absorption are affedFed and the physical properties of bags lead shot and other solids are materially different thanla liquid. If a packaging passes the drop test when tested with bags of lead shot an$ liquid, but would fail if tested with water or a liquid substance with the same properties as the material to be transported, the results of the test have been affected. Thus, bags of lead shot are not a suitable additive. You may petition for a rule change if you believe that a modification shohld be considered. Procedures for submitting a petition for rulemaking are in 5 106.95. I hope this answers your inquiry. Sincerely, Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2DEPARTMENT OF THE ARMY W A M t L W S T l t S SUPPORT ACTIVITY REDSTONE ARSENAL. AL -91-7466 REPLY TO ATTENTION OF July 10,2008 Logistics Testing and Applications Division Mr. Edward T. Mazzulo Director, Office of Standards US Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor, PHH-10 1200 New Jersey Avenue SE Washington, DC 20590 Dear Mr. Mazzulo: This letter of inquiry for interpretation is written on behalf of the US Army Materiel Command Logistics Support Activity Packaging, Storage, and Containerization Center (USAMC LOGS A PSCC), Tobyhanna, Pennsylvania. The USAMC LOFSA PSCC Packaging Applications Testing Facility is a packaging test facility for the U.S. Depfutment of Defense (DoD) where military and commercial packaging testing, including, hazardous materials packaging UN certification testing, has been performed to military, industry, commercial, and item or material test methods for 60 years. This letter is being written for a clarification/interpretation of the requirements of the Hazardous Materials Regulations (HMR) stated below. It is asked that an interpretation be provided that restricts test substances for liquid lading to only liquids having the same or higher Specific Gravity as water (Se1.0), and that solids not be permitted as a replacement test product for liquids. §I 78.6020) "For the drop and stacking test, inner and single-unit receptacles must be filled to not less than 95% of maximum capacity in the case of solids and not less than 98v of maximum in the case of liquids. The material to be transported in the packagings may be replaced by a non- hazardous material, except for chemical compatibility testing or where this would invalidate the results of the tests. " $1 78.602(c) ''lfthe material to be transported is replaced for test purposes by a non-hazardous material, the material used must be of the same or higher specific gravity as the material to be carried, and its other physical properties (grain, size, viscosity) which might influence the results of the required tests must correspond as closely as possible to those of the hazardous material to be transported. Water may also be used for the liquid drop test under the conditions specified in $1 78.603te) of this subpart. It ispennissible to use additives, such as bags of lead shot, to#

Page 3achieve the requisite totalpaclcage mass, so long as they are placed so that the test results are not aflected. " This facility routinely uses either water or antifreeze and water solutions for all packaging testing containing liquids. However, it is common practice in private industry to use lead shot andlor other solids in place of, or along with, liquids for testing. In the aforementioned paragraphs of the HMR it is permissible to use bags of lead shot, to achieve the requisite total package mass, so long as they are placed so that the test results are not aflected. However, from this facility's 60 years of experience in packaging testing for DoD, it can be stated that-- Bags of lead shot cannot be placed in such a way so as to not affect drop test results. The load distribution andlor center of gravity are different than when only liquid is used, and Bags of lead shot cannot be placed in such a way so as to not affect drop test results, inasmuch as the bags of lead shot (other loose materials) absorb shock before the inner packaging sees the shock, and Lead shot or other solids, such as steel bolts, do not have the samephysicalproperties as liquids and should not be used as a replacement test lading for liquids. A solid is not a liquid, and does not behave as such. When using water or other liquids having a Specific Gravity 2 1 .O, the drop heights and stacking top load already incorporate the Specific Gravity of the intended lading in the calculations for the drop and stack test parameters per the applicable paragraphs in the HMR. Point of contact for this matter is Ms. Charlotte A. Lent, (570) 895-7160, fax (570) 895-7823, or e-mail charlotte.lent@,us.armv.mil. All correspondence responding to this memorandum should be sent to Chief, USAMC LOGSA Packaging, Storage, and Containerization Center (AMXLS-ATIMs. Charlotte A. Lent), 1 1 Hap Arnold Boulevard, Tobyhanna, PA 18466-5097. Sincerely, ' JAMES R. BRYANT Chief, Logistics and Engineering Center#