{"operation":"document","citation":"09-0024","title":"Lia BD Consulting — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-02-13","effective_on":null,"summary":"09-0024 response to Lia BD Consulting concerning 172.101, 175.10.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0024.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0024.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0024","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2009/090024.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\npipeline and Hazardous\nMaterials Safety\nAdministration FEB I 3 2009\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr.Bamy Lia, Ph.D.\nLia BD Consulting\n93 14 40th Ave. N.E.\nSeattle, WA 98 1 1 5\nRef. No.: 09-0024\nDear Dr. Lia:\nThis is in response to your e-mail requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171 - 180) regarding applicability to aqueous solutions of\nsilver nitrate and iron sulfate. Specifically, you ask us to confirm that an aqueous solution of\n0.25 % silver nitrate (0.015 M) and an aqueous solution of 0.25 % iron sulfate (0.008 M) in\ncontainers not more than 100 milliliters each do not meet the criteria for a hazardous material\nunder the HMR.\nYour understanding is correct. The concentration of the quantity of material per inner\ncontainer, as described in your e-mail, does not meet the criteria for a hazardous material\nunder the HMR and, therefore, is not subject to the HMR.\nI hope this information is helpful. Please contact this office if you have additional questions.\nSincerely,\natt tie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<>>\n\n175 18\nDrakeford, Carolyn \nP--\" 10- . - -\nFrom,: INFOCNTR \nSent: Monday, January 26,2009 2:12 PM\nTo: Drakeford, Carolyn \nSubject: FW: query about checked baggage materials <<#280774-377849#>>\nFrom: Barry Lia [mailto:barrylia@comcast.net]\nSent: Sunday, January 25,2009 9:59 PM\nTo: INFOCNTR \nSubject: Fwd: query about checked baggage materials <<#280774-377849# > >\nDear Hazardous Materials Information Center,\nRepeating what I wrote in my query to the Transportation Security Administration (TSA) below:\nI am planning a trip from Seattle (SEA) to California (SF0 or SMF) the end of February, in order to\nattend a small conference. At this conference, I am to demonstrate a paper chromatography method for\nquality testing of vegetable juices (cited in Tingstad, Quality and Method: Risingpictures in evaluation\nof food quality, Gads Forlag 200 1 .) This is for educational purposes.\nMy kit includes glassware (24 glass dishes about 2.5 inches in diameter), pipet, papers, and two small\nbottles of solution. I am planning to pack this kit within my checked bag (NOT my carry-on bag). It\nwill be packed in a solid metal photo gear case about 6\"xl2\"x18\" within my checked bag. I will also\npack one 2 liter bottle of purified water in my checked bag.\nThe solutions are 0.25% silver nitrate (0.015M) and 0.25% iron sulfate (0.008 M), no more than 100\nmilliliters each. They are not flammable or disabling chemicals. I understand from the MSDS\ninformation fiom Sigma-Aldrich, that silver nitrate solution is hazardous to the aquatic\nenvironment. These are the precautions for a 2.5% solution of sodium nitrate (mine are ten times less\nconcentrated):\nToxic to aquatic organisms\nMay cause long-term adverse effects in the aquatic environment\nThis material andlor its container must be disposed of as hazardous waste\nAvoid release to the environment\nI will be packing waste solution back home for disposal at our county hazardous waste center.\nTransportation in both directions will be in a solid, padded photo gear case.\nI have a PbD. in neurobiology. I have handled material much more hazardous in my career. J am\nbeing preemptive, seeking to avoid incurring trouble with safety or security regulations and having my\ndemonstration materials held up or confiscated.\nI am looking for a statement that neither of these solutions (0.01 5 M silver nitrate or 0.009 M iron\nsulfate) present a hazard precluding their airline transport in my checked bag, that they are not\nflammable or disabling chemicals and, therefore, that they should not be confiscated by\nTSA officials.\nI trust that the TS A has steered me to the correct office for this ruling.\nThe US Department Of Transportation's Hazardous Materials Regulations (49 Code of Federal Regulation, Parts 100-185) are written, issued, and\nofficially interpreted by the US DOT Pipeline and Hazardous Materials Safety Administration. Office of Hazardous Materials Safety\n~ttp:lhazmat.dot.aov).\nTherefore, we also encourage you to contad the Hazardous Matelials Information Center at: 1-800-467-4922 or ~_nfocntr@doL.gov for assistance with\nspecific questions or comments regarding these regulations and hope that this information was helpful\nI can be reached at 206-753-9244.\nThank you for your attention,\n\n<<>>\n\nPage 2 of 3\nBarry Lia, Ph.D. \\ Lia BD Consulting\nbamyliabcomcast.net \\ Seattle WA\n9314 40th Ave NE, Seattle WA 981 15 \\ 206-522-1937\nBegin forwarded message:\nFrom: 'TSA-ContactCentef' \nDate: January 22, 2009 12:41:43 PM PST\nTo: ~barrvliaBcomast.nef>\nSubject: Re: query about checked baggage materials W280774-377849#**\nThank you for your e-mail.\nThe Aviation and Transportation Security Act (ATSA) established the Transportation Security Administration\n(TSA) and mandated deadlines for enhanced security measures.\nIncrementally, TSA worked to meet its mandates and at the same time provide an increased level of customer\nsewice. As changes and enhancements to aviation security were implemented, TSA publicized Traveler Tips to\naid travelers with the enhanced screening process. To inform travelers of changes to the checked baggage\nscreening process, TSA introduced suggestions that may assist travelers with the new procedures.\nTSA recommends that passengers not pack food items (e.g.: water) in their checked luggage. While the\npractice is not prohibited, some food items have properties that may cause one or more baggage screening\nmethods to alarm. Hand screenirlg of the luggage will be required to clear every alarm. Travelers who pack food\nitems in checked baggage may do so with the understanding that this may cause delays for themselves andlor\ntheir baggage.\nIn general, the US Department of Transportation (DOT) regulations prohibit passengers and crewmembers from\ncarrying hazardous materials (e.g.:silver nitrate and iron sulfate) aboard commercial aircraft. In addition, the US\nDepartment Of Transportation's Hazardous Materials Regulations (49 Code of Federal Regulation, Parts 100-\n185) are written, issued, and officially interpreted by the US DOT Pipeline and Hazardous Materials Safety\nAdministration, Office of Hazardous Materials Safety (htt~://hazmat.dot.nov).\nTherefore, we also encourage you to contact the Hazardous Materials Information Center at: 1-800-467-4922\nor infocntr@dot.~ov. for assistance with specific questions or comments regarding these regulations and hope\nthat this information was helpful.\nWe encourage you to visit our website at m,tsa.gov for additional information about TSA. add new information and encourage you to check the website frequently for updated information.\nWe continue to\nTSA Contact Center\n-- Original Message --\nFrom: \"Barry Lia\" \nReceived: 1120109 12:31:35 PM EST\nTo: \"TSA Contact Center\" \nSubject: query about checked baggage materials\nDear TSA,\nI am planning a trip from Seattle (SEA) to California (SF0 or SMF) the end of February, in order to attend a small\nconference (see below). At this conference, I am to demonstrate a paper chromatography method for quality testing of\nvegetable juices (Saturday afternoon on Agenda below).\nMy kit includes glassware (24 glass dishes about 2.5 inches in diameter), pipet, papers, and two small bottles of solution. I\nam planning to pack this kit within my checked bag (NOT my carry-on bag). It will be packed in a solid metal photo gear case\nabout 6\"x12x18\" within my checked bag. I will also pack one 2 liter bottle of purified water in my checked bag. The solutions\n\n<<>>\n\nPage 3 of 3\nare 0.25% silver nitrate and 0.25% iron sulfate, no more than 100 milliliters each. They are not flammable or disabling\nchemicals.\nLooking over the TSA and FAA websites, it appears to me that this would be acceptable. The only possible exception may\nbe that the water bottle is larger than 16 ounces? If so, could I repackage the same amount of water in smaller bottles? Would\nfour 500 milliliter bottles (1 6.9 oz) pass?\nI am looking forward to your ruling,\nBarry Lia \\ barrvlia@comcast.net \\ Seattle WA\n9314 40th Ave NE, Seattle WA 981 15 \\ 206-522-1937\n----- TCC Control Number: -----\nca80774-377849#>>","truncated":false,"body_characters":8382}