{"operation":"document","citation":"09-0037","title":"Thermo Fisher Scientific — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-10-21","effective_on":null,"summary":"09-0037 response to Thermo Fisher Scientific concerning 171.1, 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0037.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0037.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0037","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090037.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\nOCT 2 1 2009\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMr. Gene Sanders, DGSA\nSenior Dangerous Goods Transportation Specialist\nThermo Fisher Scientific, Customer channel Group\n2000 Park Lane\nPittsburg, Pennsylvania 15275\nRef. No. 09-0037\nDear Mr. Sanders:\nThis responds to your e-mail regarding the classification of hydrogen gas at low pressure\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically,\nyou ask whether the HMR apply to the transportation of a small quantity of hydrogen inside a\nglass tube or sphere if the hydrogen is shipped at a reduced pressure, rather than compressed.\nAccording to the information provided with your email, the hydrogen gas is shipped within a\nglass tube with a total capacity of 1.7 ml. The gas is shipped at a pressure lower than\natmospheric pressure (75 tom). In the event that the glass tube or sphere were to break, the\namount of hydrogen released (0.17 ml) would be insufficient to ignite (i.e., in a 1 -inch\ndiameter tube or sphere, the concentration of the hydrogen would be below the 4% LEL).\nIt is the opinion of this office that when packaged as described in your e-mail, the hydrogen\nis not shipped in a quantity and form that poses an unreasonable risk to health and safety or\nproperty and, therefore, is not subject to regulation under the HMR.\nI hope t h s satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nCharles E. Betts\nStandards Development\nof Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nSpectrum tubes with Hydrogen Page 1 of 1\nDrakeford, Carolyn <PHMSA>\nw.\"-..-.-e-* .\"\"\",*-- \"--- ..\"-*---- \"- e m - -.\nFrom: Gorsky, Susan <PHMSA>\nSent: Wednesday, February 18,2009 7:20 AIM\nTo: Drakeford, Carolyn <PHMSA>\nSubject: FW: Spectrum tubes with Hydrogen\nFrom: Sanders, Gene [mailto:gene.sanders@thermofisher.com]\nSent: Tuesday, February 17, 2009 4:41 PM\nTo: Gorsky, Susan <PHMSA>\nCc: Mayfield, John\nSubject: Spectrum tubes with Hydrogen\nDear Ms. Gorsky,\nThermo Fisher has a product that includes 1.7 mL of hydrogen gas at low pressure, 75 Torr, approximately\n1110 of an atmosphere, inside a glass tube. In the event that the glass tube were to be broken, the hydrogen\nwould return to atmospheric pressure, and its volume would become 0.17 mL, approximately one half of 1% of an\nounce. As the hydrogen diffuses into air in a sphere 1 inch across, it becomes too dilute to ignite, (i.e., in a 1 inch\ndiameter sphere, the concentration of that much hydrogen would be below the 4% LEL).\nBecause of the extremely small quantity of hydrogen in this article, and because it is shipped at a reduced\npressure rather than compressed, we do not believe that it poses an unreasonable risk to health, safety, or\nproperty when shipped in commerce, and therefore is not a hazardous material for transport. Does PHMSA\ndisagree with this classification?\nThank you.\nCheers,\nGene Sanders, DGSA\nSenior Dangerous Goods Transportation Specialist\nThermo Fisher Scientific, Customer Channels Group\n2000 Park Lane\nPittsburgh, Pa. 15275 USA\nGene.Sanders@ThermoFisher.com\n41 21490-8934, cell 4121498-2458, fax 41 21490-8930\nwww.thermofisher.com\nThe world leader in serving science\nWORLDWIDE CONFIDENTIALITY NOTE (Optional): Dissemination, distribution or copying of this e-mail or the information herein by anyone other than\nthe intended recipient, or an employee or agent of a system responsible for delivering the message to the intended recipient, is prohibited. If you are not\nthe intended recipient, please inform the sender and delete all copies. ' .'Cr..","truncated":false,"body_characters":3668}