# Hazwaste Packaging Consultants — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 13-0198
- **title:** Hazwaste Packaging Consultants — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2014-02-20
- **effective on:** Not available
- **summary:** 13-0198 response to Hazwaste Packaging Consultants concerning 173.24, 173.24a, 173.24b, 173.412.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0198.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0198.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0198
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130198.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
FEB 2 0 2014
Mr. Robert White
Owner/CEO
Hazwaste Packaging Consultants
PO Box 209
Lenoir City, TN 37771-0209
Reference No. 13-0198
Dear Mr. White:
This is in response to your September 19, 2013 letter requesting clarification ofthe Hazardous
Materials Regulations (HMR; 49 CPR Parts 171-180) applicable to packaging. Your questions
are paraphrased and answered below:
Q 1: You state that in the absence of a reduced atmospheric pressure chamber, you internally
pressurize a Type A packaging containing a radioactive material to 11.1 pounds per
square inch (psi), close the air supply, and monitor the pressure gauge for a period of 5
minutes. You ask ifthe packaging is considered to have met the requirements in
§ 173.412(£) for reduction of ambient pressure if there is no loss in pressure for the 5
minute period.
A1: The requirement in§ 173.412(£) for demonstrating whether a package can withstand
reduction of ambient pressure to 25 kPa (3 .6 psi) is a design capability requirement. As
required by§ 173.412(£), the containment system must retain its radioactive contents
under the reduction of ambient pressure to 25kPa (3 .6 psi).
Q2: You state that§ 173.410(£) references§§ 173.24, 173.24a, and 173.24b. You ask if
§§ 173.24, 173.24a, and 173.24b all apply to both bulk and non-bulk packages.
A2: Non-bulk packages would be subject to the packaging requirements in§§ 173.24 and
173.24a; bulk packages would be subject to the requirements of§§ 173.24 and 173.24b.
Q3: You state that the packaging that is most commonly tested for Department of Energy
(DOE) sites is a 96 cubic foot container filled to a gross weight of 11,000 pounds. You
further state that the packaging can be designed and tested as an IP-1, IP-2, IP-2, 7 A
Type A, or 7 A Type A, Fissile Qualified. You ask whether a 96 cubic foot container
would be considered a bulk packaging. Additionally, you ask if this packaging is
considered a non-bulk package, would it be permissible to test a single package to meet
the vibration test as required by§ 178.608.

<<<PAGE 2>>>

A3: PHMSA defines a bulk packaging in § 171.8 as having a net mass greater than 400 kg
(882 pounds). Since your packaging has a gross weight of 11,000 pounds it would be
considered a bulk packaging under the HMR. A vibration test for a bulk packaging is
not required under § 178.608.
I hope this satisfies your request.
Sincerely,
~7~~~---
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

<<<PAGE 3>>>

HAZWASTE
PACKAGING
CONSULTANTS
4nclrews
~ /73 , J.};o{f)
.g 113 · ~ cf; September 19 2013
?, 173. (2'-114. '
&173 .;;;J/h
7oeJ<cpqes
I!J-o;Y;g
U.S. DOT
PHMSA Office of Hazareous Materials Standards
Attn: PHH-10
East Building
1200 New Jersey Avenue, SE.
Washington, DC 20590-0001
Dear Sirs,
I have two (2) questions pertaining to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
QUESTION 1:
Reference 49 CFR 173.412(f), Reduction of Ambient Pressure.
In the absence of a reduced atmospheric pressure chamber, we internally pressurize a Packaging to
11.1 psig (14. 7 psi atmospheric pressure - 3.6 psi reduced ambient pressure = 11.1 psi), close the air
supply, and monitor the Pressure Gauge for a period of 5-minutes. If there is no loss in pressure for the
5-minute period, the Packaging is considered to have passed the Test. Is this an acceptable method?
QUESTION 2:
Reference 49 CFR 173.410(f), Vibration
a. 173.410(f) says "The package will be capable of withstanding the effects of any acceleration,
vibration, or vibration resonance that may arise under normal conditions of transport without any
deterioration in the effectiveness of the closing devices on the various receptacles or in the integrity
of the package as a whole and without loosening or unintentionally releasing the nuts, bolts, or other
securing devices even after repeated use. (see§§ 173.24, 173.24a, and 173.24b)."
i. 173.24(f)(1) says, "Closures on packagings shall be so designed and closed that under
conditions (including the effects of temperature, pressure, and vibration) normally incident to
transportation, .... there is no release of material and the closure is leakproof.
ii. 173.24a(5) says, "Vibration. Each non-bulk package must be capable of withstanding, without
rupture or leakage, the vibration test procedure specified in 178.608 of this subchapter."
iii. 173.24b does NOT require vibration testing
2a. Since 173.410(f) states: "see§§ 173.24, 173.24a, and 173.24b," are all Packagings subject to all three
paragraphs? As I read it, 173.24 applies to all packagings, bulk and non-bulk; 172.24a applies to non-
bulk packagings only; 173.24b applies to bulk packagings only.
2b. The Packaging that is most commonly tested for DOE Sites is 4' x 4' x 6' = nominal 96 cubic feet, with a
filled gross weight of 11,000 lbs. (This size Packaging can be designed and tested as an IP-1, IP-2, IP-
3, 7A Type A, or 7A Type A, Fissile Qualified.) Is this a bulk packaging? If so, then I understand that the
CFRs do not require a Vibration Test as specified in 178.608. Is this correct?
2c. IF a Vibration Test IS required, since there is no Vibration Test Machine that I know of large enough to
handle three (3) of the above Packages simultaneously, because of both physical size and weight, is it
permissible to use a single Package on the Vibration Table for the Test?
Thank you for your help.
Sincerely,
Robert G. White
Owner/CEO
Hazwaste Packaging Consultants
PO Box 209
Lenoir City, TN 37771-0209
(865)- 235-6555
- **truncated:** false
- **body characters:** 5669