{"operation":"document","citation":"11-0020","title":"Department of the Air Force — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-07-25","effective_on":null,"summary":"11-0020 response to Department of the Air Force concerning 173.27, 178.608.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0020.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0020.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0020","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110020.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department 1200 New Jersey Avenue SE\nWashington, DC 20590\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration 'JUL 2 52011\nMs. Robbin L. Miller\nDepartment ofthe Air Force\n403 SCMS/GUEB\n5215 Thurlow st. Ste. 5\nWright-Patterson AFB OH 45433-5540\nReference No.: 11-0020\nDear Ms. Miller:\nThis responds to your letter requesting clarification ofthe Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to the hydrostatic pressure and\nleakproof ness requirements for a combination package transported via aircraft.\nSpecifically, you describe a scenario and ask several questions regarding that scenario.\nThe scenario and questions are paraphrased and answered as follows:\nIn your incoming letter, you describe a combination packaging composed of a 30-gallon\nsteel drum lined with a 4-mil plastic bag containing a I-gallon plastic bottle surrounded by\nvermiculite. This completed combination package has been tested to the Packing Oroup\n(PO) I level. The combination package was subjected to and successfully passed the stack,\ndrop and vibration tests specified in Subpart M ofPart 178 ofthe HMR. The inner\npackaging ofthis combination packaging does not meet pressure requirements specified in\n§ 173.27( c). However, the outer packaging successfully passed a hydrostatic pressure test\nwith a test pressure of 95 kP A. You wish to transport via aircraft a PO I liquid with a\nvapor pressure of 110 kPa at 50° C in this combination packaging.\nQ1. It is your understanding of § 173.27( c)(3)(i), and a previously issued Pipeline and\nHazardous Materials Safety Administration (PHMSA) Interpretation issued on\nJuly 8, 2003 [Ref. No. 03-0163], that a PO I liquid may be transported aboard an\naircraft in the tested combination packaging described in the above scenario. Is this\ncorrect?\nAI. The answer is yes. For transportation by aircraft, § 173.27(c)(2) requires that\npackagings must be capable ofwithstanding, without leakage an intema,1 pressure\nbased on the vapor pressure of the material to be transported when its basic\nfunction is retention ofliquid. Section I 73.27(c)(3)(i) allows inner packagings that\nare not capable ofmeeting the pressure requirement to be placed in a supplemental\nouter packaging which does meet the pressure requirement. In accordance with\n§ 173.27(c)(2)(ii)(B), for transportation by aircraft of a liquid with a vapor pressure\nof 110 kP A at 50° C, the outer packaging ofa combination packaging must be\ncapable of meeting a pressure requirement. The pressure requirement is the greater\n\n<<<PAGE 2>>>\n\nof either 9S kP A or 92.S kP A if the inner packaging is not capable of meeting the\npressure requirement. Based on the requirements in § 173.27(c) the combination\npackaging you describe in your incoming letter does demonstrate it is capable of\nmeeting pressure requirements and, therefore, can be used to meet this requirement.\nQ2. If the above described PG I liquid's vapor pressure was 120 kP A at SO°C, and the\ninner packaging ofthe combination packaging does not meet any of the\nrequirements in § 173.27(c), what would the required pressure rating be for the\nouter packaging?\nA2. In accordance with § 1 73.27(c)(2)(ii)(B), for transportation by aircraft of a liquid\nwith a vapor pressure of 120 kP A at SO°C, the outer packaging ofa combination\npackaging must be capable ofmeeting a pressure requirement of 110 kP A at 50°C\nif the inner packaging is not capable ofmeeting the pressure requirement.\nQ3. It is your understanding of § 1 78.604(a)(2), that there is no leakproofness\nrequirement for either the inner or outer packaging of the packaging mentioned\nabove. Is this understanding correct?\nA3. The answer is yes. In accordance with § 1 78.604(a), the leakproofness test must be\nperformed on all packagings intended to contain liquids, except the test is not\nrequired for inner packagings of combination packagings. The outer packaging of\nthe combination packaging you describe in your letter is intended to contain the\ninner package, not liquids; thus, it is not subject to the leakproofness test specified\nin § 178.604(a). However, it should be noted that the outer package ofthis\ncombination package still must meet the requirements specified in\n§ 173.27(c)(3)(i).\nI hope this satisfies your inquiry. Please contact us ifwe can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDEPARTMENT OF THE AIR FORCE\n591 51 SUPPLY CHAIN MANAGEMENT GROUP (AFGLSC)\nWRIGHT-PATTERSON AIR FORCE BASE. OHIO\nMEMORANDUM FOR U.S. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-IO\nEast Building\n1200 New Jersey Avenue, SE.\nWashington DC 20590-000 I\nFROM: 403 SCMS/GUEB\n5215 Thurlow St. Ste. 5\nWright-Patterson AFB OH 45433-5540\nSUBJECT: Pressure Requirements for Outer Packagings ofCombination Packagings\n1. This office performs testing ofUN specification packaging for Air Force and other DOD\noffices. We request clarification ofthe issues in paragraphs 2 a and b below, concerning\nhydrostatic pressure requirements for the outer packaging of a combination packaging described\nin the following scenario.\n2. Packing Group I testing was performed on a combination packaging consisting of one 30gallon\nsteel open-head drum, lined with a 4-mil plastic bag, and containing one I-gallon plastic\nbottle, surrounded by firmly packed vermiculite. The complete packaging underwent the stack,\ndrop, and vibration tests and met all requirements. The inner packaging does not meet any ofthe\npressure requirements of 173.27(c). The outer packaging, however, has been certified by the\nmanufacturer as successfully passing a hydrostatic pressure test with a test pressure of95 kPa\n(14 psig). The PG I liquid to be transported in this combination packaging is authorized to be\ntransported aboard aircraft, and its vapor pressure at 50°C is 110 kPa.\na) It is our understanding of I 73.27(c)(3)(i), and PHMSA Interpretation 03-0163, that the PG I\nliquid may be transported aboard aircraft in the tested combination packaging described above.\nOr, in other words, this drum may be used as the outer packaging for PG I, II, and III liquids for\nall transportation modes (vapor pressure as above, or lower). Is this correct?\nb) Ifthe above PG I liquid's vapor pressure was, for example, 120 kPa at 50°C, and the inner\npackaging doesn't meet any of the pressure requirements of 173.27( c), what would the required\npressure rating for the above drum be?\n3. In addition, it is our understanding of 1 78.604(a)(2), that there is no leakproofness test\nrequirement for either the bmer or outer packagings of the above combination packaging. Is this\ncorrect?\n\n<<<PAGE 4>>>\n\nI\n4. Thank you in advance for your assistance. If clarification of the scenario or any of the\nquestions is needed, our point ofcontact is Ms. Susan Evans, GUEB, 937-257-7445.\nFOR THE COMMANDER\nR~XJ1/d4\nROBBIN L. MILLER\nChief, AF Packaging\nTechnology & Engineering Facility","truncated":false,"body_characters":7000}