DuPont Global Logistics — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and. Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 FEB 1 0 2014 Mr. Kevin Greene Hazardous Materials Consultant DuPont Global Logistics P.O. Box 525 Axis, AL 36505 Reference No.: 13-0209 Dear Mr. Greene: This is in response to your November 5, 2013 letter and conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the HMR authorize the installation of a 2 inch bung/vent into a UN 1H1 plastic drum that would permit air to enter the drum, but not allow the release of hazardous material from the drum. You note that the drum will be fitted with the bung/vent prior to subjecting it to the tests specified in Part 178. The HMR authorize openings for filling, emptying or venting in UN 1H1 plastic drums in accordance with the provisions of§ 173.24(g). Please note that except for shipments of cryogenic liquids as specified in§ 173.320( c) and of carbon dioxide, solid (dry ice), venting of packages is not permitted when transportation by aircraft is involved. When venting is authorized, provided the drum passes the appropriate design tests with the bung/vent in place and does not allow the escape of hazardous material, the opening described in your letter is acceptable. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Duane Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2DuPont Global Logistics P.O. Box525 Axis, Alabama 36505 DuPont Global Logistics 05 November 2013 Mr. T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division Attn: PHH-1 0 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 Request a written formal interpretation regarding the usEt of vents on plastic 1H1 drums as provided in 173.24(g)(1)(2)(3) of the HMR. Dear Mr. Foster: I have a 55-gallon plastic drum (1 H1/Y1.9/150) that will be used to transport a class 9 liquid (Marine Pollutant) by sea and air. The drum will be fitted with a 2" bung/vent that will allow air to enter the drum but will not allow any liquid or gas to exit the drum. The purpose of the vent is to allow air to enter the drum to avoid drum paneling (e.g. slight sucking-in or collapsing) of the plastic drum body due to methyl soyote scavenging air from the head space. Based on my understanding of the provisions provided in part 173.24(g)(1 )(2)(3) of the HMR, I may install a vent on my plastic drum that will allow air to enter the plastic drum but will not permit any hazardous (i.e. poisonous, flammable)liquid or gas to exit the drum. Is my understanding correct? I hope this information is helpful. Please contact me if you require additional assistance. Kevin M. Greene Hazardous Materials Consultant DuPont Global Logistics P.O.Box 525 Axis, Alabama 36505 Phone: (251) 679.5330 Kevin.m.greene@dupont. com#