{"operation":"document","citation":"08-0184","title":"Department of the Army, USAMC LOGSA Packaging Storage and Containerization Center — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-08-18","effective_on":null,"summary":"08-0184 response to Department of the Army, USAMC LOGSA Packaging Storage and Containerization Center concerning 178.602.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0184.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0184.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0184","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080184.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nAUG 1 8 2P38\n1200 New Jersey Ave. S E\nWash~nqton DC 20590\nMs. Charlotte A Lent\nChief, USAMC LOGSA Packaging\nStorage and Containerization Center\n11 Hap Boulevard\nTobyhanna, PA 18466-5097\nRef. No.: 08-0 1 84\nDear Ms. Lent\nThis is in response to your July 10,2008 letter regarding non-bulk performance-oriented\npackage testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180).\nSpecifically, you ask if the HMR restrict test substances for non-bulk packages designed to\ncontain a liquid hazardous material to liquids having the same or higher)specific gravity than\nwater and prohibit the substitution of solid materials as a replacement te:st product for liquids.\nAccording to 5 178.602(c), it is permissible to use additives, such as bags of lead shot, to\nachieve the requisite total package mass so long as they are placed so that the test results are\nnot affected. You suggest that bags of lead shot cannot be placed in a way that will not affect\ndrop test results because load distribution and shock absorption are affedFed and the physical\nproperties of bags lead shot and other solids are materially different thanla liquid.\nIf a packaging passes the drop test when tested with bags of lead shot an$ liquid, but would\nfail if tested with water or a liquid substance with the same properties as the material to be\ntransported, the results of the test have been affected. Thus, bags of lead shot are not a\nsuitable additive.\nYou may petition for a rule change if you believe that a modification shohld be considered.\nProcedures for submitting a petition for rulemaking are in 5 106.95.\nI hope this answers your inquiry.\nSincerely,\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nDEPARTMENT OF THE ARMY\nW A M t L W S T l t S SUPPORT ACTIVITY\nREDSTONE ARSENAL. AL -91-7466\nREPLY TO\nATTENTION OF\nJuly 10,2008\nLogistics Testing and Applications Division\nMr. Edward T. Mazzulo\nDirector, Office of Standards\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nEast Building, 2nd Floor, PHH-10\n1200 New Jersey Avenue SE\nWashington, DC 20590\nDear Mr. Mazzulo:\nThis letter of inquiry for interpretation is written on behalf of the US Army Materiel\nCommand Logistics Support Activity Packaging, Storage, and Containerization Center\n(USAMC LOGS A PSCC), Tobyhanna, Pennsylvania. The USAMC LOFSA PSCC Packaging\nApplications Testing Facility is a packaging test facility for the U.S. Depfutment of Defense\n(DoD) where military and commercial packaging testing, including, hazardous materials\npackaging UN certification testing, has been performed to military, industry, commercial, and\nitem or material test methods for 60 years.\nThis letter is being written for a clarification/interpretation of the requirements of the\nHazardous Materials Regulations (HMR) stated below. It is asked that an interpretation be\nprovided that restricts test substances for liquid lading to only liquids having the same or\nhigher Specific Gravity as water (Se1.0), and that solids not be permitted as a\nreplacement test product for liquids.\n§I 78.6020)\n\"For the drop and stacking test, inner and single-unit receptacles must be filled to not less\nthan 95% of maximum capacity in the case of solids and not less than 98v of maximum in the\ncase of liquids. The material to be transported in the packagings may be replaced by a non-\nhazardous material, except for chemical compatibility testing or where this would invalidate\nthe results of the tests. \"\n$1 78.602(c)\n''lfthe material to be transported is replaced for test purposes by a non-hazardous material,\nthe material used must be of the same or higher specific gravity as the material to be carried,\nand its other physical properties (grain, size, viscosity) which might influence the results of the\nrequired tests must correspond as closely as possible to those of the hazardous material to be\ntransported. Water may also be used for the liquid drop test under the conditions specified in\n$1 78.603te) of this subpart. It ispennissible to use additives, such as bags of lead shot, to\n\n<<<PAGE 3>>>\n\nachieve the requisite totalpaclcage mass, so long as they are placed so that the test results are\nnot aflected. \"\nThis facility routinely uses either water or antifreeze and water solutions for all packaging\ntesting containing liquids. However, it is common practice in private industry to use lead shot\nandlor other solids in place of, or along with, liquids for testing. In the aforementioned\nparagraphs of the HMR it is permissible to use bags of lead shot, to achieve the requisite total\npackage mass, so long as they are placed so that the test results are not aflected. However,\nfrom this facility's 60 years of experience in packaging testing for DoD, it can be stated that--\nBags of lead shot cannot be placed in such a way so as to not affect drop test results. The\nload distribution andlor center of gravity are different than when only liquid is used, and\nBags of lead shot cannot be placed in such a way so as to not affect drop test results,\ninasmuch as the bags of lead shot (other loose materials) absorb shock before the inner\npackaging sees the shock, and\nLead shot or other solids, such as steel bolts, do not have the samephysicalproperties as\nliquids and should not be used as a replacement test lading for liquids. A solid is not a\nliquid, and does not behave as such.\nWhen using water or other liquids having a Specific Gravity 2 1 .O, the drop heights and\nstacking top load already incorporate the Specific Gravity of the intended lading in the\ncalculations for the drop and stack test parameters per the applicable paragraphs in the HMR.\nPoint of contact for this matter is Ms. Charlotte A. Lent, (570) 895-7160, fax (570) 895-7823,\nor e-mail charlotte.lent@,us.armv.mil. All correspondence responding to this memorandum\nshould be sent to Chief, USAMC LOGSA Packaging, Storage, and Containerization Center\n(AMXLS-ATIMs. Charlotte A. Lent), 1 1 Hap Arnold Boulevard, Tobyhanna, PA 18466-5097.\nSincerely,\n' JAMES R. BRYANT\nChief, Logistics and\nEngineering Center","truncated":false,"body_characters":6211}