Guidanceguidance
11-0290
Department of the Army — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration FEB 082012 1200 New Jersey Avenue SE Washington. DC 20590 Ms. Sarah Gedrich Chief, LOGSA Packaging, Storage, and Containerization Center (AMXLS-AT-L) Department of the Anny 11 Hap Arnold Boulevard Tobyhanna, PA 18466-5097 Ref. No. 11-0290 Dear Ms. Gedrich: This responds to your October 12, 2011 letter requesting clarification of the preparation of composite or combination packaging containing compressed oxygen and other oxidizing gases in cylinders or chemical oxygen generators for testing under the Hazardous Materials Regulations (HMR; 49 CFR Part 171-180). In general terms, these articles are required to be placed in a rigid outer packaging that conforms to the testing provisions in Part 178, Subpart M ofthe HMR or the performance criteria of Airlines for America (A4A), formerly the Air Transport Association of America, Inc. (AT A) , Specification No. 300 for a Category I shipping container. See §§ 173.168(d)and 173.302(f)(3). You specifically request clarification ofthe preparation ofpackaging for testing. Your questions are paraphrased and answered in a single response as follows, however, we note that the guidance offered relative to A4A Specification No. 300 is the opinion of this Office and we recommend that you contact A4A for further guidance: Q. Should the testing be conducted with the cylinder and chemical oxygen generator empty? If so, how are we to account for the weight ofthe material in a filled cylinder or chemical oxygen generator? A. Yes. Additives similar to the instruction provided in § 178 .602( c) ofthe HMR can be used to compensate for the weight ofthe hazardous contents. I hope this answers your inquiry. Ifyou need additional assistance, please contact this Office at (202) 366-8553. S~'~~ Ben Supko Acting Chief, Standards Development Branch Standards and Rulemaking Division#
Page 2ber kin cJ-eren DEPARTMENT OF THE ARMY SIll. g USAMC LOGISTICS SUPPORT ACTIVITY REDSTONE ARSENAL, ALABAMA 35898-7466 S175.lfog 25 }7<6 . idJz- October 12, 2011 eM WI ica ( 0}(J~ ~ n (b~r1tra.1oo {t-D2/10 Logistics Testing and Applications Division Mr. Charles E. Betts Director, Office of Hazardous Materials Standards U.S. DOTIPHMSA (PHH-10) 1200 New Jersey Avenue SE East Building, 2nd Floor Washington, DC 20590 Dear Mr. Betts: This letter of inquiry for interpretation is written on behalf of the US Army Materiel Command Logistics Support Activity Packaging, Storage, and Containerization Center (USAMC LOGSA PSCC), Tobyhanna, PA. It is being written for clarificat,ioniinterpretation ofthe HM224B, Hazardous Materials Regulations (HMR): Transportation ,of Compressed Oxygen, Other Oxidizing Gases and Chemical Oxygen Generators on Aircraft. ' The Title 49 Code of Federal Regulations (CFR) §17L~ defines all o~ter packaging as "the outermost enclosure of a composite or combination packaging together with any absorbent materials, cushioning and any other components necessary to contain and protect inner receptacles or inner packagings." In order to meet the "integrity standards," the HM-224B requires that the cylinder or the generator "must be placed in a rigid outer packaging that (1) Conforms to the requirements of either: (i) Part 178, subparts L and M, ofthis subchapter at the Packing Group I or II performance level; or (ii) The performance criteria in Air Transport Association (AT A) Specification No. 300 for a Category I shipping container." (49 CFR § 173.168 and § 173. 304) As written, subparts L and M do not address the preparation of packagings for testing if one was to designate the cylinder or generator as the inner packaging and the HM224B specification packaging as the outer packaging. Typically, the package would be required to be closed "in the same manner as if prepared for transportation" (49 CFR § 178.602). For the packaging being discussed, this could be 115 cubic feet of oxygen compressed to pressures greater than 3,000 pounds per square lnch <psi) (for tests other than the drop and stack tests). The 49 CFR addresses filling procedures for packages subjected to the drop and stack tests, and in relation'to liquids and solids only. . Compressed gas has a behavior different' from either a liquid or a..~olid~@d the safety risks involved with testing pressurized cylinders are extreme. '.'''3'[' ';< . .. .#
Page 3-2• Should the cylinder or generator be tested empty? If empty, how do we account for the extra weight once filled (2 lbs to greater than 20 Ibs depending on the size ofthe cylinder)? ATA Specification No. 300 Category I does not address the preparation for packaging. • Should the cylinder or generator be tested empty under these requirements as well? Point of contact for this matter is Miss Sarah R. Gedrich, DSN 795-7649, (570) 615-7649, FAX (570) 615-7823, or e-mail sarah.gedrich@us.arrny.mil. All correspondence responding to this memorandum should be sent to Chief, LOGSA Packaging, Storage, and Containerization Center (AMXLS-AT-LiSarah Gedrich), 11 Hap Arnold Boulevard, Tobyhanna, PA 18466-5097. Sincerely, jf1 d·JL~~ sh~~rnith"VVV Chief, Logistics Testing and and Applications Division#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.