{"operation":"document","citation":"10-0012","title":"Detector Electronics Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-03-01","effective_on":null,"summary":"10-0012 response to Detector Electronics Corporation concerning 172.101, 173.115, 173.132.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100012.pdf","body":"<<>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMAR 1 2010\nMr. Jon Varner\nDirector of Engineering\nDetector Electronics Corporation\n6901 West 1l0lh Street\nMinneapolis, Minnesota 55438\nRef. No. 10-0012\nDear Mr. Vamer:\nThis responds to your email dated January 12,2010 requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). Your company manufactures a gas\ndetection device designed to detect hydrogen sulfide (H2S). The calibration method for the H2S\ngas detection device requires the use ofglass ampoules containing H2S. Specifically, you ask\nPHMSA to confirm that based on the LCso value, the method of packing, and shipment quantities,\nthe H2S ampoules are transported in a form and quantity that does not pose an unreasonable risk\nto health and safety or property, and therefore are not subject to the HMR.\nYou provide the following supplemental information:\nEach ampoule has a volume of 7 ml and is filled with H2S, which based on your calculations\nis equivalent to a concentration of 0.49%. You have determined through calculations that\nthe LCsoofthe H2S mixture contained in each glass ampoule is 145,510 ml/m3\n• The\nampoules are packed in blocks of foam, 6 ampoules per block. Two foam blocks are packed\nper corrugated outer box. These boxes are then overpacked in a box with 300 Ibs. burst\nstrength with additional packing material, andlor other items, Shipments typically include\n100 ampoules and are not anticipated to exceed 1,000 ampoules,\nA Division 2.3 (gas poisonous by inhalation) material is defined as a gas that is known to be so\ntoxic to humans as to pose a hazard to health during transportation; or, in the absence of data on\nhuman toxicity, is presumed to be toxic to humans because when tested in a laboratory it has an\nLCso of 5,000 mllm3\n, Based upon the calculated LCso, the material you describe in your letter\n\n<<>>\n\ndoes not meet the definition of a Division 2.3 material. Therefore, provided the material does not\nmeet the definition of any other hazard class, it is not subject to the requirements of the HMR.\nI hope this answers your inquiry. If you need further assistance, please contact this office at 202366-8553.\nSincerely,\n~~i~\n~\nCharles E. Betts\n. f, Standards Development\nOffice ofHazardous Materials Standards\n\n<<>>\n\n~ DET.TRONICS®\n6901 West 11 Oth Street Detector Electronics Corporation\nMinneapolis, MN 55438 USA\nTel 952.941.5665 Fax 952.829.8750\nA UTe Fire & Security Company\nwww.det-tronics.com f..; c £1eVl laA-b\nJanuary 12, 2010 S 113. 13 Z\nMr. Charles E. Betts\n~ 172. I 0 1 fJ , 73 . \" S-\nChief, Standards Development Cta~5if, c.a..:h 0(\\\nOffice of Hazardous Materials Standards 10· 00/0\nPipeline and Hazardous Materials Safety Administration\nAttn: PHH-10\nU.S. Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nRe: Request for Advisory Opinion on the Hazardous Classification of H2S Ampoules\nDear Mr. Betts:\nDetector Electronics Corporation (DEC) manufactures safety solutions including flame\ndetection, gas detection and safety systems for use in hazardous industrial applications. As\npart of our industrial gas detection product line, we manufacture a line of toxic gas detectors\nwhich require routine calibration to ensure detection accuracy. The method for calibration of\nour hydrogen sulfide (H2S) gas detectors involves the use of glass ampoules containing a\nsmall quantity of H2S., and the purpose of this letter is to confirm our view that transportation\nof the ampoules is not subject to DOT's Hazardous Materials Regulations (\"HMR\") for the\nreasons discussed below.\nThe ampoules are filled with a specified mixture of H2S and nitrogen and sealed under partial\nvacuum. The calibration is performed by inserting the sensor into a 700 mL chamber and\nbreaking the ampoule in the closed cylinder. The released mixture from the ampoule diffuses\ninto the closed chamber yielding a concentration of 50 ppm H2S. The detector's output is\nthen adjusted accordingly to ensure accurate measurement of gas leaks in the field\napplication. Pictures of the calibration set up are included as Exhibit 1 and 2.\nFor the following reasons, DEC does not believe that these ampoules pose a significant\nhazard during transportation. Each ampoule contains 2.5% H2S in a 7 mL ampoule filled\nunder negative pressure of one fifth normal atmospheric pressure. This is equivalent to a\nconcentration of 0.49% as shown by the following equation:\n2.5% H2S * 760 Torr\n150 Torr = 0.49% H2S\n~\n...\nr\n,\n,\nSubpart D §173.115(c)(2) describes a gas mixture as gas poisonous by inhalation (Division\n2.3) when the LCso value is not more than 5,000 mUm. Using the formula defined in\n§173.133(b)(1 )(i):\n(100%) (713 ppm)\nLC50 of a DEC H2S ampoule = = 145,510 mUm3\n0.49%\nWhere LCso of H2S =713 ppm (IDLH 7783064 NIOSH)\n\n<<>>\n\nA DET.TRONICS®\n6901 West 11Ott! Street Detector Electronies Corporation\nMinneapolis, MN 55438 USA\nTeI952.941.5665 Fax 952.829.8750\nwww.det-tronies.com\nA UTC Fire & Security Company\nThus, the LC50 of each DEC H2S ampoule is 145,510 mUm3 which is significantly greater than\nthe defined 5,000 mUm3 threshold in Section 173.115(c)(2) of the HMR.\nThe packaging for the ampoules is designed for maximum protection to limit breakage during\ntransport. The ampoules are packed in blocks offoam (10 x 10 x 7.5 em), six ampoules to a\nblock (see Exhibit 3). Two foam blocks are packed per corrugated cardboard box (10 x 10 x\n15 cm) or a maximum of 12 ampoules per box (see Exhibit 4 and 5). These boxes are then\nover packed in a box with 300 Ibs. burst strength with additional packing material and/or other\nitems. An MSDS describing the properties and exposure effects of H2S is included with each\nshipment. Shipments would typically include fewer than 100 ampoules and are not\nanticipated to exceed 1,000 ampoules. To put this information into context of an example\nshipment, if 3,000 ampoules (three times the expected maximum shipment) were broken in a\n1 m x 1 m x 1 m container with no ventilation, the concentration in the container would reach\nonly 103 ppm. It would take 20,970 ampoules all broken at the same time in a 1m3 container\nfor the concentration to reach the LC50 of 713 ppm.\nBased on the LC50 value of 145,510 mUm3 per ampoule, the method of packing, and shipment\nquantities, DEC believes that the ampoules are shipped in a form and quantity that does not\npose an unreasonable risk to health and safety or property, and therefore are not classified as\nhazardous under 49 CFR Parts 170 - 199. The analysis and the classification of ampoules as\nnon-hazardous is consistent with a 1994 letter to General Monitors, Inc. from Edward\nMazzullo, Director of the Office of Hazardous Materials Standards. Copies of the General\nMonitors request, and the response, are attached as Exhibit 6. We are requesting that DOT\nconfirm our assessment regarding the ampoules.\nQuestions regarding the information provided in this letter may be directed to the undersigned\nat 952 946-6464.\nSincerely,\n~m~\nDirector of Engineering\nDetector Electronics Corporation\n6901 West 110th Street\nMinneapolis, MN 55438\nEnclosures\n\n<<>>\n\nExhibit 1 Ampoule Calibration Set-Up\n0.0 8PM\nA DET TRONICS\nNTMOS $5\nNeq-Flex\n\n<<>>\n\nLID\n..c\nE\nro\n..c\nU\nc\no\n+='\nro\nL..c\nro\nU\nN\n:t::\n..c\n..c\nx\nLU\n\n<<>>\n\nE\nro\no\nLL\nC\n(/)\nQ)\n:::J\no\na.\nE\n~\n(\"f)\n:~\n.0\n..c\nX\nW\n\n<<>>\n\n0>\nC\n.::,t;.\nU\nco\na..\nE\nco\no\nu.\n\"¢\n. ~\n..0\n..c\nX\nW\n\n<<>>\n\n~\nx\no\nCO\nQ)\no\n0..\nE\n«\n'U\nQ)\n(J\nCO\na..\nL()\n:t:\n.c\n.r:.\nx\nW\n~\n\n<<>>\n\nExhibit 6 GMI Letter and DOT Response\nof Transportation\nUS. Departmens\nResearch and\npecial Program\ndministratio\nJUl 1 8 001\nMr. Khanh Dang\nResearch Chenist\nGeneral Monitors, Inc.\n26776 simpatica Circle\nE1 Toro, CA 92630\nDear Mr. Dang:\nThis is in response to your letter of May 5, 1994, requesting\nampoules.\ninformation\non the classification of hydrogen sulfide (HS)\nYou state that each ampoule contains a 1.78ł concentration of HS\nmixed with nonpressurized nitrogen as a diluent. Each ampoule will\nof HS in a 250 ml container. Quantities of 12 or 100 ampoules are\nsimulate an exposure of a maximum amount of 500 parts per million\ndividers.\npacked in a carton,\nThese cartons are then overpacked in another corrugated\nwith each ampoule packed in corrugated\ncarton, filled with packing material.\nof the HS, the fact the ampoules are not under pressure, and the\nIt is the opinion of this office that, based on the concentration\nmanner the material is packaged, the ampoules of HS would not pose\na significant hazard during transportation and, therefore, are not\nsubject to the Hazardous Materials Regulations (49 CFR Parts 171-\n180) •\nsincerely,\nDirector,\nMaterials Standards\nOffice of Hazardous\n\n<<>>\n\nExhibit 6 GMI Letter and DOT Response\n~~~ I ~l.a.(/\"tF:\\i~\n\\'1 132~~\n) lorffJb~ ~ SOOOmUm3\nwhere LC50 eo 713 ppm (pg.. 280 o(Toxie and lb.zardous, 1985)\nMix.tur~ ~~ ~ (l QQ)all~.~ u::;~~\nS.OOOmUm\nGMt's =-mpouln: Concentration o(eacb ampoules.. 7 mL'\" (SQ2.Wm)(lSO rot) <:> 17.857 ppm\n7m)\n% Volume per ampoules ~ 17.8S7 ppm c> 1.73%\nlO,OOOppmfOlo\nMixture of LCSO a 009%)(71) ppm) t:f 40.0S6 mlIm3\n1.78%\n•\nTherefore, GMrs ampoules each contain onJy I 78% onus with an LCSO value of\n40,056 mUm3\n, which is significantly greater lhan 5,000 mUm3\n.\n\n<<>>\n\ndoes not meet the definition of a Division 2.3 material. Therefore, provided the material does not\nmeet the definition of any other hazard class, it is not subject to the requirements of the HMR.\nI hope this answers your inquiry. If you need further assistance, please contact this office at 202366-8553.\nSincerely,\n~i[~\n~\nCharles E. Betts\n. f, Standards Development\nOffice ofHazardous Materials Standards","truncated":false,"body_characters":11111}