{"operation":"document","citation":"13-0031","title":"Minigrip — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-03-25","effective_on":null,"summary":"13-0031 response to Minigrip concerning 173.124, 173.134.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0031.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0031.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0031","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130031.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMAR 2 5 2013\nMr. Ben Hellming\nMini grip\n161 Kimball Bridge Road\nAlpharetta, GA 30009\nRefNo.: 13-0031\nDear Mr. Hellming:\nThis is a response to your January 25, 2013 email and subsequent telephone conversation\nwith a member of my staff requesting clarification of the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 1 00-185) with regard to general packaging requirements. Specifically,\nyou request confirmation that a packaging that your company has designed, which will not\ncontain hazardous materials, voluntarily complies with the venting requirements for\npackaging specified in§ 173.24(g)(2).\nIn your email, you include a description of your packaging and pictures of the packaging\nconfiguration. The packaging is considered a combination packaging and consists of a\nprimary leak-proof container to hold specimens, packed in a secondary bag that has been\nfitted with a pressure release patch, which is further placed in a rigid outer container. The\npackage is marked with orientation arrows. Additionally, the bag has printed language\nstating \"do not cover pressure release patch.\" You indicate that the primary leak-proof cups\nas well as the secondary bag have both been tested to withstand a 95 kPa internal pressure\ntest.\nBased on the telephone conversation with my staff, these packages are meant to hold\nspecimens (e.g. blood and urine) that do not meet the definition of any hazard class,\nincluding Division 6.2, Infectious Substance and are not subject to the l=IMR. While these\nmaterials are not required to be shipped in conformance with the HMR, you intend for your\npackaging to voluntarily comply with the general packaging requirements in§ 173.24(g)(2).\nIt should be noted that the venting requirement in§ 173.24(g)(2) is not a standalone\nrequirement. In order for a packaging to fully comply with the venting requirements of the\nHMR, the packaging must conform to all requirements of§ 173.24(g).\nThe purpose of§ 173.24(g) is to allow for the venting of packages to reduce internal\npressure, which may develop by the evolution of gas from the contents. For all non-bulk\npackaging venting is only permitted under the following conditions: (1) except for\nshipments of cryogenic liquids as specified in§ 173.320(c) and of carbon dioxide, solid (dry\n\n<<<PAGE 2>>>\n\nice), transportation by aircraft is not involved; (2) except as otherwise provided in this the\nHMR, the evolved gases are not poisonous, likely to create a flammable mixture with air or\nbe an asphyxiant under normal conditions of transportation; and (3) the packaging is\ndesigned so as to preclude an unintentional release of hazardous materials from the\nreceptacle.\nIt also be should be noted that if the packaging is intended to contain materials classified as\nDivision 6.2 (infectious substances), the requirements ofthe applicable packaging section\nfor the specific category of infectious substance(§§ 173.196, 173.197, and 173.199) must\nalso be met. Furthermore, § 173.134 provides exceptions from the HMR for potentially\ninfectious substances such as blood and urine.\nI hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this office.\nSincerely,\nRobert Benedict\nChief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nJNFOCNTR (PHMSA)\nMonday, January 28, 2013 1:45 PM\nDrakeford, Carolyn (PHMSA)\nFW: Jetter of Interpretation 173.24 G2\nMinigrip Image Slide Show- 95kPA Bags- 25Jan13.wmv\n5uc}1ak\n~ 17 3. :< l..j\nPa~ka3 in3s\n13 -oo3/\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Bennett Hellming [mailto:ben.hellming@minigrip.com]\nSent: Friday, January 25, 2013 4:25 PM\nTo: INFOCNTR (PHMSA)\nSubject: letter of Interpretation 173.24 G2\nTo U.S. Department of Transportation:\nWe are launching a new 95 kPa specimen transport bag for air transportation of blood and laboratory samples and want\nto be sure we understand the regulations with respect to our product and application.\nWe are a provider of liquid bio-hazard shipping bags used for blood vials and urine cups. Our package is a secondary\npackage- see attached picture. The primary container (blood vial and urine cup) is leak proof (and many times 95 kPa\nrated). The primary container goes into our secondary package (used to tie patient paperwork to sample) and then goes\ninto a rigid outer container. Our shipping bag survives the 95 kPa internal pressure test by use of a pressure release patch\nthat allows the bag to vent when the bag expands and contracts during pressure changes during air transportation.\nIn the worst case scenario that the primary leak proof container leaks, out-gassing from the contents would be non-\nflammable, non-poisonous and not an asphyxiate. The pressure release patch also contains an antimicrobial agent. Any\nliquid leaking from the primary leak proof container would be contained in our absorbent system designed to absorb\nmore liquid then would be transported in the bag.\nTo prohibit blockage of pressure release patch during shipping, the outer rigid container has 'this side up arrows' to\nensure that the pressure release patch is oriented correctly and the bag has printed language stating 'do not cover\npressure release patch' during shipping.\nOur bag passed a 95 kPa internal pressure test conducted by Southeast Testing & Enginee!ring, Lawrenceville, GA, a DOT\ncertified 3rd party certification lab.\nWe are requesting a DOT Letter of Interpretation that states that Minigrip 95 kPa bag is compliant with 49 CFR 173.24 G2\nfor our product.\nThank you,\nBen Hellming\nGeneral Manager\n1\n\n<<<PAGE 4>>>\n\nP 770 422 4187 Ext. 111\nc 770 335 3411\nben.hellming@minigrip.com\n2","truncated":false,"body_characters":5891}