{"operation":"document","citation":"08-0193","title":"LaMotte Co. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-09-04","effective_on":null,"summary":"08-0193 response to LaMotte Co.; URS Corporation concerning 173.306, 173.4.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0193.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0193.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0193","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080193.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave. S E.\nWashington, DC 20590\nSEP 2 2008\nMs. Erin N. Jarman\nEnvironmental Scientist\nURS Corporation\n1600 Perimeter Park Drive\nMorrisville, NC 27560\nRef. No. 08-0193\nDear Ms. Jarman:\nThis is in response to your July 24, 2008 letter requesting further clarification of our letter to\nyou dated June 20, 2008 concerning the packaging requirements for transporting non-\npressurized gas under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180).\nIn your April 28,2008, you asked whether shipping gas samples in \"Tedlar\" bags placed in a\none-quart metal can (similar to a paint can) with a friction lid sealed with plastic-ring seals is,\npermissible under the HMR. You also provided a copy of the product documentation for the\nfriction lid metal cans indicating a hydrostatic test rating of 100kPa. In your most recent\nletter, you ask whether our response is the same if the hydrostatic test rating is 95 kPa instead\nof 100 kPa.\nThe answer is yes. Section 173.306(a)(4)(iii) requires non-pressurized gases, flammable to\nbe packed in hermetically sealed glass or metal inner packagings of not more than 5 L (1.3\ngallons) and overpacked in a strong outer packaging. Section 17 1.8 defines \"hermetically\nsealed\" as closed by fusion, gasketing, crimping, or equivalent means, so that no gas or vapor\ncan enter or escape. It is the opinion of this Office that a metal can with a hydrostatic test\nrating of 95 kPa and a friction lid sealed with plastic-ring seals as described in your letter\nmeets the definition of \"hermetically sealed,\" and therefore can be used as an inner\npackaging as specified in 4 173.306(a)(4)(iii).\nI hope this information is helpful.\nSincerely,\n(.-, L - '\n,+ I - > \\.\nSusan Gorsky, ij\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nJuly 24,2008\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. Mazzullo:\nI am writing to you with regards to a clarification I recently received regarding the proper packaging\nneeded for the purpose of transporting non-pressurized, flammable gas samples in Tedlar@ bags. In\nthe response fiom your office dated June 20,2008 (Ref. No. 08-0139) it was confirmed that a metal\ncan with a friction lid sealed with a plastic-ring seal that had been tested to a hydrostatic test rating\nof 100kPa would indeed meet the definition of \"hermetically sealed and would therefore be an\nacceptable inner packaging as required by 9 173.306(a)(4)(iii).\nUpon further research, I have discovered that many can manufacturers state that their cans have been\nhydrostatically tested to only 95kPa, rather than the 100kPa presented in my initial interpretation\nrequest. I was wondering if it would still be the opinion of your office that a metal can with a\nfkiction lid and sealed with a plastic-ring seal with a hydrostatic test rating of 95kPa would still meet\nthe definition :;f \"hermetically sealed\" and would therefore still be an acceptable inner packaging as\nrequired by 173.306(a)(4)(iii).\nThank you in allvance for your assistance. I look forward to your response.\nSincerely,\nErin N. Jarman\nEnvironmental Scientist\nURS 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":3482}