CH2MHILL Plateau Remediation — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue BE U.S. Department Washington. DC 20590 of Transportation Pipeline and Hazardous Materials Safety Administration MAR 3 0 2012 Mr. Chris Backus Packaging engineer Transportation Safety CH2MHILL Plateau Remediation Company P.O. Box 1600MSIN T3-ll Richland, W A 99354 Ref. No.: 11-0289 Dear Mr. Backus: This responds to your e-mail regarding the definition 'of"lifting attachment" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-80) used to lift and properly secure Class 7 (radioactive) material packagings onto a conveyance. Subsequently, you provided pictures and diagrams of the packaging. You provided a scenario as follows: As your company often lifts steel boxes with a fork truck by placing the fork arms' inside pockets on the container bottom, are the fork pockets and the surrounding structural framework ofthe metal container considered a "lifting attachment that is a structural part ofthe package." "Would it then follow that all ofthese steel structural members (e.g., C-Channels, sheet metal, structural tubing, etc.) must have a minimum safety factor ofthree against yielding when used to lift the package with the fork truck." Specifically, you ask what is meant by "lifting attachment" as used in §173.41 O(b), and whether fork pockets and the surrounding structural framework on steel boxes would be considered to be lifting attachments. Each package used for the shipment ofClass 7 (radioactive) materials must be designed so that the package can be easily handled and properly secured in or on a conveyance during transportation. Section 173.41 O(b) requires that each package used for the shipment ofClass 7 (radioactive) materials must be designed so that- Each lifting attachment that is a structural part ofthe package must be designed with a minimum safety factor ofthree against yielding when used to lift the package in the intended manner, and it must be designed so that failure of any lifting attachment under excessive load would not impair the ability ofthe package to meet other requirements ofthis subpart. Any other structural part of#

Page 2the package which could be used to lift the package must be capable ofbeing rendered inoperable for lifting the package during transport or must be designed with strength equivalent to that required for lifting attachments. As you note the boxes are often lifted by placing the arms ofa fork truck into the pockets, the pockets would be considered to be lifting attachments. Other structural members that could not reasonably be used to lift the package by a fork truck or other means would not be considered to be lifting attachments. Any other structural part ofthe package must be capable of being rendered inoperable for lifting the package during transport or must be designed with strength equivalent to that required for lifting attachments (see §173.41O(b». I hope this information is helpful. Ifwe can be of further assistance, please contact us. Sincerely, Ben Supko Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) 11- 02S9 Sent: Monday, November 14, 2011 3:39 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: 49 CFR 173.41 O(b) interpretation requested Hi Carolyn, We received the following request for a letter of interpretation. Thanks, Victoria Victoria Lehman Hazmat Information Center (HMIC) http://phmsa.dot.gov/hazmat/info-center (202) 366-1035 From: Backus, Christopher L [mailto:Christopher L Backus@RL.gov] Sent: Wednesday, November 09, 2011 3:27 PM To: INFOCNTR (PHMSA) Subject: 49 CFR 173,410(b) interpretation requested 97-0239 Completed by Ae via phone on 11/14/11 at 12:05 left vm PHMSA Office of Hazardous Materials Safety: 49 CFR 173.410(b) states "Each lifting attachment that is a structural part of the package". There is some ambiguity as to the definition of "lifting attachment". We are asking if you can give a precise definition, as we often lift steel boxes with a fork truck by placing the fork arms inside of fork pockets on the container bottom. Are the fork pockets and the surrounding structural framework of the metal container considered a "lifting attachment that is a structural part of the package"? Would it then follow that all of these steel structural members (e.g. C-Channels, sheet metal, structural tubing, etc.) must have a "minimum safety factor of three against yielding when used to lift the package" with the fork truck? Kind Regards, Chris Backus Packaging Engineer Transportation Safety PO Box 1600 MSIN T3-11, Richland, WA 99354 Phone:509-373-2678 Fax:509-373-4051 1#

Page 4Engrum. Helen (PHMSA) From: Backus, Christopher L [ChristophecL_Backus@rl.gov] Sent: Tuesday, February 21, 2012 11 :55 AM To: Engrum, Helen (PHMSA) Subject: Example of a Structure with openings for Forklift Tines Attachments: Fork Pocket Container Example.pdf Hi Helen, Please find attached a photo and sample sheet of a drawing for a container where forklift tines may be inserted beneath the container and the container structure used to support the weight of the container. Thanks, Chris Backus Packaging Engineer Transportation Safety PO Box 1600 MSIN T3-11, Richland, WA 99354 Phone:509-373-2678 Fax:509-373-4051 e-mail: Christopher L Backus@rl.gov 1#

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