{"operation":"document","citation":"11-0274R","title":"Department of the Army — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-11-13","effective_on":null,"summary":"11-0274R response to Department of the Army concerning 173.168, 173.302, 173.304.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0274r.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0274r.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0274r","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2011/110274R.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nNOV 1 3 2013\nMs. Sarah Gedrich\nChief, LOGSA Packaging, Storage, and Containerization\nCenter (AMXLS-AT-L)\nDepartment of the Army\nII Hap Arnold Boulevard\nTobyhanna, PA I8466-5097\nRef. No. JI-0274R\nDear Ms. Gedrich:\nThis responds to your October I3, 20Il letter requesting clarification of the package testing\nrequirements for composite or combination packagings that contain compressed oxygen and\nother oxidizing gases in cylinders or chemical oxygen generators under the Hazardous\nMaterials Regulations (HMR; 49 CFR Part I71-I80). In general terms, these articles are\nrequired to be placed in a rigid outer packaging that conforms to the testing provisions in Part\n178, Subpart M of the HMR or the performance criteria of Airlines for America (A4A),\nformerly the Air Transport Association of America, Inc. (ATA), Specification No. 300 (\"Spec\n300\") for a Category I shipping container. See§§ I73.168(d), 173.302(£)(3) and I73.304(f)(3).\nYou specifically request clarification of the testing and performance criteria and determination\nof successful test results.\nYour questions regarding Part 178, Subpart M testing are paraphrased and answered as follows:\nQ I. The HMR outline package preparation criteria for testing. For example, inner receptacles\nfor liquid material must be at least 98% filled (see§ 178.602(b)). However, there is no\ncriterion for gases. How would cylinders be filled to 98% with a gas?\nA I. The physical properties of a gas would not allow for a cylinder to be filled to 98%. The\nfilling criteria for inner receptacles intended to contain liquid or solid material do not apply to\ngases. Bear in mind that these drop tests should not be conducted with filled cylinders because\nof the inherent safety risks associated with a compressed gas.\nQ2. Following drop tests of composite or combination packaging, the absence of leakage of\nfilling material from the inner receptacles signifies a successful test (see§ 178.603(±)(4)). If\nthe drop test were to be conducted with empty cylinders, how would it be determined if the\nmaterial leaked?\nA2. The cylinder should be filled after the drop test to determine whether there is any leakage\nas a result of damage occurring during the drop test.\n\n<<<PAGE 2>>>\n\nQ3. If damage to the outer packaging affects the flame penetration resistance, is this\nconsidered an unsuccessful test?\nA3. Yes. This would be considered damage likely to adversely affect safety during\ntransport.\nQ4. Would the same criteria apply to the stacking test and the vibration standard?\nA4. Yes. The responses to questions 1 thru 3 hold true for both the stacking test and\nthe vibration standard.\nYour questions regarding A4A Spec 300 and testing are paraphrased and answered as follows,\nhowever, we note that the guidance we present in this letter relative to A4A Spec 300 was\noffered from consultation with A4A and we recommend that you contact A4A for further\nguidance regarding this standard:\nQ 1. Regarding the drop test of a Category I shipping container (that can be handled\nmanually in transportation), are the drops conducted on each side, edge, or corner, in\nsequence or only on one selected side, corner, and edge?\nA 1. The drop test is to be performed in sequence for the required number of drops for\neach side and repeated for the required number of drops for each edge and each corner.\nThe combination of 160 side (face) drops distributed among the six (6) sides, 80 edge\ndrops distributed among the twelve (12) edges, and 40 corner drops distributed among\nthe eight (8) corners must total 280 drops. Care should be taken under the test plan to\naddress worst case scenarios (e.g., unevenly loaded boxes) when distributing the drops\nin each case.\nQ2. Regarding the cause for rejection, if the cylinders are considered the contents, how\nis it determined that the contents do not show any changes that affect their utility.\nA2. The determination of any \"changes affecting the utility of the contents\" would be\nsimilar to determination of successful testing under the HMR. That is, the cylinder\nshould be filled after the drop test to determine whether there is any leakage.\nQ3. Are the required tests to be performed in series?\nA3. No. Each test type (e.g., drop, vibration, etc.) must be completed independent of\nthe others.\n\n<<<PAGE 3>>>\n\nQ4. Should the utility of the packaging be determined after each test type (e.g., drop,\nvibration, etc.)?\nA4. Yes. The contents of the packaging are to be inspected after the testing procedure\nfor each test type is complete to determine whether they show any changes that affect\ntheir utility.\nI hope this answers your inquiry. If you need additional assistance, please contact this Office at\n(202) 366-8553.\nSincer1y, . . . .\n\"Jfl,{_L~\nharles Betts,\nirect_or,\nStandards and Rulemaking Division\n\n<<<PAGE 4>>>\n\nDEPARTMENT OF THE ARMY\nUSAMC LOGISTICS SUPPORT ACTIVITY\nREDSTONE ARSENAl, ALABAMA 35898-7466\nOctober 13, 2011\nLogistics Testing and Applications Division\nMr. Charles E. Betts\nDirector, Office of Hazardous Materials Standards\nU.S. DOT/PHMSA (PHH-1 0)\n1200 New Jersey Avenue\nSE East Building, 2nd Floor\nWashington, DC 20590\nDear Mr. Betts:\nThis letter of inquiry for interpretation is written on behalf of the US Army Materiel\nCommand Logistics Support Activity Pac~aging, Storage, an.ci qo~tainerization Center (USAMC\nLOGSA PSCC), Tobyhanna, PA. It is being written for clariticationlinter_Pretation.ofthe HM-\n224B,'Hazardous Materials Regulations (HMR): Transportation o{c;ompr~ssed Oxygen, Other\nOxidizing Gases and Chemical Oxygen Generators on .Aircr,aft·. , · · · ·\nThe Title 49 Code of Federal Regulations (CFR) § 171.8 defi~es ·an outer packaging as \"the\noutermost enclosure of a composite or combination packaging, together with any absorbent\nmaterials, cushioning and any other components necessary to contain and protect inner\nreceptacles or inner packagings.\" In order to meet the \"integrity standards,\" the HM-224B\nrequires that the cylinder 9r the generator\n\"must be placed in a rigid outer packaging that -\n(1) Conforms to the requirements of either:\n(i) Part 178, subparts Land M, of this subchapter at the Packing Group I\nor II performance level; or\n(ii) The performance criteria in Air Transport Association (AT A)\nSpecification No. 300 for a Category I shipping container.\" (49 CFR\n§173.168 and §173. 304)\nAs written, subparts L and M do not clearly address criteria for passing a drop test, if\none was to designate the cylinder or generator as the inner packaging and the HM-224B\nspecification packaging as the outer packaging. Specifically for a composite or\ncombination packaging states that the outer packaging \"must not exhibit ~y damage\nlikely to affect safety dUring transport. Inner receptacles, inner packagings, and art~cles\nmust remain completely withiri the outer packaging and there must be no leakage of\nfilling substance from the inner receptacle or inner packagings.\" For the packaging being\ndiscussed, this could be 115 cubic feet of oxygen compressed to pre~sures gr~ater than\n3,000 pounds per square inch (psi) inside an HM-224B outer p~cka~ing. The.49 CFR\naddresses filling procedures for packages subjected to the drop in relation to liquids and\n' • . .. ~ l . . ' • ' ' .\n\n<<<PAGE 5>>>\n\nDEPARTMENT OF THE ARMY\nUSAMC lOGISTICS SUPPORT ACTIVITY\nREDSTOf'IE ARSENAL, ALABAMA 35898·7466\nOctober 13, 2011\nLogistics Testing and Applications Division\nMr. Charles E. Betts\nDirector, Office of Hazardous Materials Standards\nU.S. DOT/PHMSA (PHH-10)\n1200 New Jersey Avenue\nSE East Building, 2nd Floor\nWashington, DC 20590\nDear Mr. Betts:\nThis letter of inquiry for interpretation is written on behalf of the US Anny Materiel\nCommand Logistics Support Activity Packaging, Storage, ami Co~tainerization Center (USAMC\nLOGSA PSCC), Tobyhanna, PA. It is being written for clariticatio:n!i.nterpretation.ofthe HM-\n224B,Hazardous Materials Regulations (HMR): Transportation ofGompressed Oxygen, Other\nOxidizing Gases and Chemical Oxygen Generators on .Airc~a:(t. · . · · ·\nThe Title 49 Code of Federal· Regulations (CFR) § 171.8deflnes an outer packaging as \"the\noutermost enclosure of a composite or combination packaging, together with any absorbent\nmaterials, cushioning and any other components necessary to contain and protect inner\nreceptacles oi: inner packagings.\" In order to meet the \"integrity standards,\" the HM-224B\nrequires that the cylinder 9r the generator\n\"must be placed in a rigid outer packaging that -\n(1) Conforms to the requirements of either:\n(i) Part 178, subparts Land M, of this subchapter at the Packing Group I\nor II performance level; or\n(ii) The performance criteria in Air Transport Association (ATA)\nSpecification No. 300 for a Category I shipping container.\" (49 CFR\n§173.168 and §173. 304)\nAs written, subparts L and l\\1 do not clearly address criteria for passing a drop test, if\none was to designate the cylinder or generator as the inner packaging and the HM-224B\nspecificati?J! 'packaging as the outer pa~kaging. Specifically for a composite or\ncombination packaging states that the outer packaging \"must not exhibit any damage\nlikely to affect safety dUring ·transport. lniler receptacles, inner' packagings, and art~cles\nmust remain completely within the outer packaging and there must be no leakage of\nfilling substance from the inner receptacle or inner packagings.\" For the packaging being\ndiscussed, this could be 115 cubic feet of oxygen compressed to pressures gr~ater than\n3,000 pounds per square inch (psi) inside an HM-224B outer patka~irig. The. 49 CFR\naddresses filling procedures for packages subjeded to the drop in relation to liquids and\n: . • • • •• ~· J . ' • . '\nl!i\n\n<<<PAGE 6>>>\n\n-2-\nsolids only. Compressed gas has a behavior different from either a liquid or a solid, and\nthe safety risks involved with testing pressurized cylinders are extreme.\n• How would the cylinder be filled to 98%?\n• If the cylinder were tested empty, how would you know if the filling substance\nleaked?\n• If the damage to the outer packaging effects the flame penetration resistance, is\nthat considered a fail?\n• Would the same criteria apply to vibration and stack test?\nATA Specification No. 300 Category I requires 160 face drop tests, 80 edgewise drop\ntests, and 40 cornerwise drop tests.\n• Are the drop tests conducted on consecutive sides, edges, or comers, or is one\nselected and the required number of drops only performed on that side, edge, or\ncomer?\nATA Specification No. 300 Category I states the cause for rejection: \"At the conclusion of\nthe testing, the contents of the container, its interior shock-absorbing materials and devices shall\nnot show any changes that affect their utility. The interior or exterior of the container shall not\nreveal any failure of the container or shifting of the part.\"\n• If a cylinder were considered the contents, how would its unaffected utility be\ndetermined?\n• Are the tests conducted in series?\n• Should the utility be tested after each test- drop, vibration, etc.?\nPoint of contact for this matter is Miss Sarah R. Gedrich, DSN 795-7649, (570) 615-7649,\nFAX (570) 615-7823, or e-mail sarah.gedrich@us.army.mil. All correspondence responding to\nthis memorandum should be sent to Chief, LOGSA Packaging, Storage, and Containerization\nCenter (AMXLS-AT-L/Sarah Gedrich), 11 Hap Arnold Boulevard, Tobyhanna, PA 18466-5097.\nSincerely,\n/b A·.~\nlsVar~ith\nChief, Logistics Testing and\nand Applications Division","truncated":false,"body_characters":11554}