{"operation":"document","citation":"14-0136","title":"5N Plus Wisconsin, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-10-24","effective_on":null,"summary":"14-0136 response to 5N Plus Wisconsin, Inc. concerning 173.28, 178.503.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0136.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0136.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0136","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140136.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\nOCT 2 4 2014\nMs. Laura Buholca\nPlant Manager\nSN Plus Wisconsin, Inc.\n6474 Blanchar's Crossing\nWindsor, WI 53598\nRef. No. 14-0136\nDear Ms. Buholca:\nThis responds to your July 11, 2014 request for clarification on the reuse of metal and plastic\ndrums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically, you ask if you need a wall thickness marking on the UN 1H2 drum (used as the\nouter packaging of a combination packaging) used to transport \"UN3260, Corrosive solids,\nacidic, inorganic, n.o.s. (gallium trichloride), 8, PGII,\" under the reuse provisions in\n§ 173.28(b)(4).\nIn a conversation with a member of our staff in the Hazardous Materials Information Center\n(HMIC), you asked if the wall thickness marking is required to reuse a UN 1H2 plastic drum.\nThe HMIC informed you that under § 173.28(b)(4) the wall thickness marking is required to\nbe marked on the drum if it is the outer drum of a composite packaging or a single packaging.\nIt is your understanding then that combination packaging is not required to be marked with\nthe wall thickness under the reuse provisions in § 173.28(b)(4).\nYour understanding is correct. In accordance with §§ 173.28(b)(4) and 178.503(a)(9), plastic\ndrums used as single packagings or outer packaging of composite packagings and intended to\ne reused must be marked with the minimum wall thickness of the packaging material. Thus\nplastic drum of a combination packaging is not required to be marked with the wal\nthickness. The packaging scenario you illustrate is considered a combination packaging by\ndefinition and is not required to be marked with the wall thickness under the reuse provisions\nin § 173.28(b)(4).\nI hope this answers your inquiry. If you need additional assistance, please contact this Office\nat (202) 366-8553.\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nBoothe\n178.503\n173,29\nGoodall, Shante CTR (PHMSA)\nFrom:\nINFOCNTR (PHMSA)\nMarkings f\nPackings\nSent:\nMonday, July 14, 2014 4:07 PM\nTo:\nHazmat Interps\n14-0136\nSubject:\nFW: letter of interpretation\nHi Alice and Shante,\nWe received this request for a letter of interpretation. Thanks.\n-Adam\nFrom: Laura Buholca [mailto:Laura.Buholca@5nplus.com]\nSent: Friday, July 11, 2014 3:10 PM\nTo: PHMSA HM InfoCenter\nSubject: letter of interpretation\nGood afternoon,\nI spoke to Adam earlier today and received a very good interpretation on the topic; however, in order to satisfy my\ncustomers request, I would like to receive letter of interpretation, because our goal is to be in complete compliance and\ntransport our haz mat product safely.\n5N PLUS\n1 Fastening ausche»\n\n<<<PAGE 3>>>\n\nMaterial we are shipping:\nUN3260\nCorrosive Solids, Acidic,\nInorganic, N.O.S. (Gallium Trichloride)\nCLASS 8\nPG IT\nHere is the packaging what we are using:\n- Material (7.5 kgs) is being placed in glass ampule; seal tape is applied; ampule is placed in fibreboard drum with foam\nushioning, it is packaged tight filling all space between bottle and fibreboard drum (picture on lower left); fibreboar\nrum is sealed with tape and placed in plastic bag and bad is sealed; all that is inserted into blue outer drum; foan\ncushioning fills space between fibreboard drum and blue drum; Blue drum is sealed;\nThe question is regards outer drum; drum is UN certified, but has no wall thickness identified on the drum.\nHere is the specifications for the drum:\nIH2 X225/S/12\nDABAN 9624\nMy question is - do we need a wall thickness, any additional certification or anything else possible that I've overlooked\nregards this outer drum that would limit us from re-using this drum for future shipments.\nPlease do not hesitate to contact me if there is any additional information needed.\n2 12f\nMany thanks\nLaura\nLaura Buholca | Plant Manager\n5N Plus Wisconsin Inc.\n6474 Blanchar's Crossing, Windsor, WI 53598\n170\n2\nT. 608-846-1357x8004\nF. 608-846-1394\nc. 608-512-9319\nConfidentiality: This message is intended solely for the addressee or the entity to which it is addressed and may contain information which is privileged\neproduction of this document is strictly forbidder\nconfidential or protected from disclosure. If you are not the intended recipient, please notify us immediately and destroy this document. Any use, copying o\n2","truncated":false,"body_characters":4424}