{"operation":"document","citation":"09-0062","title":"Container-Quinn Testing Laboratories, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-04-16","effective_on":null,"summary":"09-0062 response to Container-Quinn Testing Laboratories, Inc. concerning 173.197, 178.603.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0062.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0062.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0062","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2009/090062.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMr. Stephen C. Powell\nLab Director\nContainer-Quinn Testing Laboratories, Inc.\n170 Shepard Avenue\nWheeling, IL 60090\nRef. No.: 09-0062\nDear Mr. Powell:\nThis in response to your March 18,2009 letter regarding the drop test requirements specified in\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80) for a combination\npackaging intended for the transportation of regulated medical waste (RMW). The combination\npackaging consists of a UN 4H2 plastic container with an inner 3-mil polyethylene bag. You ask\nfor clarification of the failure criteria in fj 178.603(0(4) and specifically if it is acceptable for the\ninner packaging to develop punctures and Yt\" to %\" holes upon impact if there is no leakage of\nthe filling substance.\nThe answer is no. As you correctly noted in your letter, fj 178.603(0(4) states a combination\npackaging passes the drop test if there is no damage to the outer packaging likely to adversely\naffect the packaging during transport, and there is no leaking of substance from the inner\npackaging. It is the opinion of this Office that an inner packaging of a combination packaging\nthat develops punctures and ?A\" to %\" holes after the drop test does not meet the requirements in\n$178.603(f)(4) and, therefore, does not pass the drop test. The inner packaging's inability to\nresist punctures and holes during testing can be indicative of its integrity under transportation\nconditions.\nPlease note that, in accordance with 9 173.197(e)(l), plastic film bags used as inner packagings\nfor solid RMW must be marked and certified by the manufacturer as having passed the tests for\ntear resistance in ASTM D 1922, \"Standard for Tear Resistance of Plastic Film and Thin\nSheeting by Pendulum Method,\" and for impact resistance in ASTM D 1709, \"Standard for Test\nMethods for Impact Resistance of Plastic Film by the Free-Falling Dart Method.\" The film bag\nmust meet an impact resistance of 165 grams and a tear resistance of 480 grams in both the\nparallel and perpendicular planes with respect to the length of the bag.\n1 hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nCONTAINER-QUINN\nTESTING LABORATORIES, INC.\nA division of H.H. Holmes Testing Laboratories, 1nc:\n170 Shepard Avenue Wheeling, IL 60090 knd\"&\nPhone: 847-537-9470 Fax: 847-537-9098\ne-mail: spowell6j)container-quinn.com 3 17% ~03,&c)@)\nTe5-6 ny\n18 March 2009 by-006z\nMr. Edward T. Mazzullo\nDirector, Ofice of Hazardous Materials Standards\nUS DOT I PHMSA (PHH-10)\n1200 New Jersey Avenue, SE\nEast Building, 2\" Floor (PH)\nWashington, DC 20590\nMr. Mazzullo;\nRe. SA-9009004, ID Code +AX\nRMW testing of a combination package\nAfter discussion with Anthony Lima, USDOT and at his suggestion, I am requesting an interpretation\nand clarification of passlfail criteria in the testing of a Regulated Medical Waste (RIMW) container.\nWith IWr Lima as an observer, I conducted testing of a 4H2 plastic container, for use with RMW.\nDescription is as follows: UN 4H2 17-gallon oblong openhead plastic container with sliding transport\ncover containing one (1) 3-mil polyethylene red bag. Bag is secured by twisting the top and then\ntightly knotting it. Container is secured with cable ties. Test weight is 15.9kg. Drop height was 1.2M\nDuring the testing, the redbag is removed and inspected after each individual drop. 'There were some\nholes (114\" to W ) and punctures found in the bag after the drops but bag integrity was intact (bag was\nlifted completely out of the container and inspected). As per 49CFR, 178.603(9(4), \"For a composite\nor combination packaging, there is no damage ks the outw packaging likely $0 adverse@ affect safety\nduring trans~ort, and there is no leakage of t h e fillrng substance f o m the inner packaging;\" Under this\nsection, as the bag was able to contain all product within and the outer container showed no damage,\nI considered this to be a pass. Mr Lima raised a concern with the holes in the bag and whether this\ncompromised the test. This is the area that is under question, whether these holes and punctures are\nacceptable and, as the bag does contain all the inner product, if this should be considered a pass in\naccordance with the Criteria for Passing the Test as listed above.\nThank you for your assistance in this matter.\nSincerely - --+.\nStephen C. Powell\nLab Director\nContainer-Quinn Testing Laboratories, Inc.\nCc: Mr. Anthony Lima, US DOTIPHMSA","truncated":false,"body_characters":4696}