# Detector Electronics Corporation — Hazardous Materials Safety Interpretation

- **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:** Not available
- **summary:** 10-0012 response to Detector Electronics Corporation concerning 172.101, 173.115, 173.132.
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- **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:**

<<<PAGE 1>>>

U.S. Department of Transportation Pipeline and Hazardous Materials
Safety Administration
1200 New Jersey Ave, SE
Washington, D.C. 20590
MAR 1 2010
Mr. Jon Varner
Director of Engineering
Detector Electronics Corporation
6901 West 1l0lh Street
Minneapolis, Minnesota 55438
Ref. No. 10-0012
Dear Mr. Vamer:
This responds to your email dated January 12,2010 requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180). Your company manufactures a gas
detection device designed to detect hydrogen sulfide (H2S). The calibration method for the H2S
gas detection device requires the use ofglass ampoules containing H2S. Specifically, you ask
PHMSA to confirm that based on the LCso value, the method of packing, and shipment quantities,
the H2S ampoules are transported in a form and quantity that does not pose an unreasonable risk
to health and safety or property, and therefore are not subject to the HMR.
You provide the following supplemental information:
Each ampoule has a volume of 7 ml and is filled with H2S, which based on your calculations
is equivalent to a concentration of 0.49%. You have determined through calculations that
the LCsoofthe H2S mixture contained in each glass ampoule is 145,510 ml/m3
• The
ampoules are packed in blocks of foam, 6 ampoules per block. Two foam blocks are packed
per corrugated outer box. These boxes are then overpacked in a box with 300 Ibs. burst
strength with additional packing material, andlor other items, Shipments typically include
100 ampoules and are not anticipated to exceed 1,000 ampoules,
A Division 2.3 (gas poisonous by inhalation) material is defined as a gas that is known to be so
toxic to humans as to pose a hazard to health during transportation; or, in the absence of data on
human toxicity, is presumed to be toxic to humans because when tested in a laboratory it has an
LCso of 5,000 mllm3
, Based upon the calculated LCso, the material you describe in your letter

<<<PAGE 2>>>

does not meet the definition of a Division 2.3 material. Therefore, provided the material does not
meet the definition of any other hazard class, it is not subject to the requirements of the HMR.
I hope this answers your inquiry. If you need further assistance, please contact this office at 202366-8553.
Sincerely,
~~i~
~
Charles E. Betts
. f, Standards Development
Office ofHazardous Materials Standards

<<<PAGE 3>>>

~ DET.TRONICS®
6901 West 11 Oth Street Detector Electronics Corporation
Minneapolis, MN 55438 USA
Tel 952.941.5665 Fax 952.829.8750
A UTe Fire & Security Company
www.det-tronics.com f..; c £1eVl laA-b
January 12, 2010 S 113. 13 Z
Mr. Charles E. Betts
~ 172. I 0 1 fJ , 73 . " S-
Chief, Standards Development Cta~5if, c.a..:h 0(\
Office of Hazardous Materials Standards 10· 00/0
Pipeline and Hazardous Materials Safety Administration
Attn: PHH-10
U.S. Department of Transportation
East Building
1200 New Jersey Avenue, SE
Washington, DC 20590-0001
Re: Request for Advisory Opinion on the Hazardous Classification of H2S Ampoules
Dear Mr. Betts:
Detector Electronics Corporation (DEC) manufactures safety solutions including flame
detection, gas detection and safety systems for use in hazardous industrial applications. As
part of our industrial gas detection product line, we manufacture a line of toxic gas detectors
which require routine calibration to ensure detection accuracy. The method for calibration of
our hydrogen sulfide (H2S) gas detectors involves the use of glass ampoules containing a
small quantity of H2S., and the purpose of this letter is to confirm our view that transportation
of the ampoules is not subject to DOT's Hazardous Materials Regulations ("HMR") for the
reasons discussed below.
The ampoules are filled with a specified mixture of H2S and nitrogen and sealed under partial
vacuum. The calibration is performed by inserting the sensor into a 700 mL chamber and
breaking the ampoule in the closed cylinder. The released mixture from the ampoule diffuses
into the closed chamber yielding a concentration of 50 ppm H2S. The detector's output is
then adjusted accordingly to ensure accurate measurement of gas leaks in the field
application. Pictures of the calibration set up are included as Exhibit 1 and 2.
For the following reasons, DEC does not believe that these ampoules pose a significant
hazard during transportation. Each ampoule contains 2.5% H2S in a 7 mL ampoule filled
under negative pressure of one fifth normal atmospheric pressure. This is equivalent to a
concentration of 0.49% as shown by the following equation:
2.5% H2S * 760 Torr
150 Torr = 0.49% H2S
~
...
r
,
,
Subpart D §173.115(c)(2) describes a gas mixture as gas poisonous by inhalation (Division
2.3) when the LCso value is not more than 5,000 mUm. Using the formula defined in
§173.133(b)(1 )(i):
(100%) (713 ppm)
LC50 of a DEC H2S ampoule = = 145,510 mUm3
0.49%
Where LCso of H2S =713 ppm (IDLH 7783064 NIOSH)

<<<PAGE 4>>>

A DET.TRONICS®
6901 West 11Ott! Street Detector Electronies Corporation
Minneapolis, MN 55438 USA
TeI952.941.5665 Fax 952.829.8750
www.det-tronies.com
A UTC Fire & Security Company
Thus, the LC50 of each DEC H2S ampoule is 145,510 mUm3 which is significantly greater than
the defined 5,000 mUm3 threshold in Section 173.115(c)(2) of the HMR.
The packaging for the ampoules is designed for maximum protection to limit breakage during
transport. The ampoules are packed in blocks offoam (10 x 10 x 7.5 em), six ampoules to a
block (see Exhibit 3). Two foam blocks are packed per corrugated cardboard box (10 x 10 x
15 cm) or a maximum of 12 ampoules per box (see Exhibit 4 and 5). These boxes are then
over packed in a box with 300 Ibs. burst strength with additional packing material and/or other
items. An MSDS describing the properties and exposure effects of H2S is included with each
shipment. Shipments would typically include fewer than 100 ampoules and are not
anticipated to exceed 1,000 ampoules. To put this information into context of an example
shipment, if 3,000 ampoules (three times the expected maximum shipment) were broken in a
1 m x 1 m x 1 m container with no ventilation, the concentration in the container would reach
only 103 ppm. It would take 20,970 ampoules all broken at the same time in a 1m3 container
for the concentration to reach the LC50 of 713 ppm.
Based on the LC50 value of 145,510 mUm3 per ampoule, the method of packing, and shipment
quantities, DEC believes that the ampoules are shipped in a form and quantity that does not
pose an unreasonable risk to health and safety or property, and therefore are not classified as
hazardous under 49 CFR Parts 170 - 199. The analysis and the classification of ampoules as
non-hazardous is consistent with a 1994 letter to General Monitors, Inc. from Edward
Mazzullo, Director of the Office of Hazardous Materials Standards. Copies of the General
Monitors request, and the response, are attached as Exhibit 6. We are requesting that DOT
confirm our assessment regarding the ampoules.
Questions regarding the information provided in this letter may be directed to the undersigned
at 952 946-6464.
Sincerely,
~m~
Director of Engineering
Detector Electronics Corporation
6901 West 110th Street
Minneapolis, MN 55438
Enclosures

<<<PAGE 5>>>

Exhibit 1 Ampoule Calibration Set-Up
0.0 8PM
A DET TRONICS
NTMOS $5
Neq-Flex

<<<PAGE 6>>>

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<<<PAGE 10>>>

Exhibit 6 GMI Letter and DOT Response
of Transportation
US. Departmens
Research and
pecial Program
dministratio
JUl 1 8 001
Mr. Khanh Dang
Research Chenist
General Monitors, Inc.
26776 simpatica Circle
E1 Toro, CA 92630
Dear Mr. Dang:
This is in response to your letter of May 5, 1994, requesting
ampoules.
information
on the classification of hydrogen sulfide (HS)
You state that each ampoule contains a 1.78ł concentration of HS
mixed with nonpressurized nitrogen as a diluent. Each ampoule will
of HS in a 250 ml container. Quantities of 12 or 100 ampoules are
simulate an exposure of a maximum amount of 500 parts per million
dividers.
packed in a carton,
These cartons are then overpacked in another corrugated
with each ampoule packed in corrugated
carton, filled with packing material.
of the HS, the fact the ampoules are not under pressure, and the
It is the opinion of this office that, based on the concentration
manner the material is packaged, the ampoules of HS would not pose
a significant hazard during transportation and, therefore, are not
subject to the Hazardous Materials Regulations (49 CFR Parts 171-
180) •
sincerely,
Director,
Materials Standards
Office of Hazardous

<<<PAGE 11>>>

Exhibit 6 GMI Letter and DOT Response
~~~ I ~l.a.(/"tF:\i~
\'1 132~~
)<J ~ 3~1
May S, 1994
Edward Emazzullo
Director ofH.M.S,
Office of Hazard Material Standard
400 7th ~t < South West, Room 8100
Washington D.C. 20590
MAY I 8 1994
1/. /..,.
Mr. Emazzullo!
,..
1am writing.this letter in regards to a more current release from DOT concuning with
GMI's shipping policy that our HZS ampoules are non·dangerous goods, We already have
in our possesSion a letter from Thomas-J; Charlton,- ChiefStandards Division ofDOT,
stating that the way we package our HZS ampoules do not pose a significant hazard
during transponation(see anached letter). However, this letter is about 12 yeatS old and
therefore, I would like to obtain a more current release from DOT.
,
I would like to take this opponunity to explain why we consider our H2S ampoules as
non~angerous goods, First ofall, the ampoules that GMI manufacture contain a very low
concentration ofHZS mixed with nitrogen as a dil@. Each ofthese ampoules will
simulate an exposure ofa maximum amount of~O pans per million(ppm) HZS in a
250 mL container. According to the lATA 35 Editio~ HZS mlxture less than 14.3% by
volume may be classified as ·compressed gas, toxic. n.o.s., UN195S· because the
concentration ofHZS is low enough to have a LCSO value higher than 5,000 mUm3 as
calculated below ~
lATA Stand.",: MixtureofLC50C> lorffJb~ ~ SOOOmUm3
where LC50 eo 713 ppm (pg.. 280 o(Toxie and lb.zardous, 1985)
Mix.tur~ ~~ ~ (l QQ)all~.~ u::;~~
S.OOOmUm
GMt's =-mpouln: Concentration o(eacb ampoules.. 7 mL'" (SQ2.Wm)(lSO rot) <:> 17.857 ppm
7m)
% Volume per ampoules ~ 17.8S7 ppm c> 1.73%
lO,OOOppmfOlo
Mixture of LCSO a 009%)(71) ppm) t:f 40.0S6 mlIm3
1.78%
•
Therefore, GMrs ampoules each contain onJy I 78% onus with an LCSO value of
40,056 mUm3
, which is significantly greater lhan 5,000 mUm3
.

<<<PAGE 12>>>

does not meet the definition of a Division 2.3 material. Therefore, provided the material does not
meet the definition of any other hazard class, it is not subject to the requirements of the HMR.
I hope this answers your inquiry. If you need further assistance, please contact this office at 202366-8553.
Sincerely,
~i[~
~
Charles E. Betts
. f, Standards Development
Office ofHazardous Materials Standards
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