SGS North America, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, DC 20590 1200 New Jersey Avenue SE Pipeline and Hazardous Materials Safety Administration JUL 0 9 2015 Mr. Jason Sherrier : Laboratory Manager SGS North America, Inc. 291 Fairfield Ave Fairfield, NJ 07004 Reference No. 15-0074 Dear Mr. Sherrier: This is in response to your April 13, 2015 e-mail request regarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of aluminum boxes. You note that you intend to offer a non-explosive PG III solid material in a 4B aluminum box. Specifically, you ask if a 4B aluminum box can be certified without a liner being present. The answer to your question is yes. In accordance with § 178.512(b) as a part of their general design standards, aluminum boxes must be lined with fiberboard or felt packing pieces or must have an inner liner or coating of suitable material in accordance with subpart C of part 173 of this subchapter. The intent of the reference to subpart C of part 173 of the HMR is to ensure that these lining or coating requirements are applicable only to boxes intended to transport explosives. In your incoming email you reference a 52 FR 67403 rulemaking. There is no such Federal Register citation. Section 178.512 was amended by HM-215A (59 FR 67521) in December of 1994. The text provided in the preamble for proposed changes to § 178.512 in the HM-215A NPRM (59 FR 36498) states "Standards for steel and aluminum boxes would be consolidated by removing the distinction between unlined/uncoated steel or aluminum boxes and steel or aluminum boxes having an inner liner or coating. Therefore, both unlined and lined steel boxes would be identified as 4A and unlined and lined aluminum boxes would be identified as 4B. Corresponding revisions would be reflected in the packaging authorizations of Part 173." Existing non-bulk packaging authorizations (e.g. § 173.212) for certain hazardous materials will show single packaging authorizations for both "Aluminum box: 4B" and "Aluminum box with liner: 4B". If the non-bulk packaging requirements section referenced in column 8A for the material in question indicates an "Aluminum box: 4B" is an authorized single packaging the material may be offered in an aluminum box without a coating or liner.#

Page 2I trust 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 3velo 178.512(b)(2) Goodall, Shante CTR (PHMSA) Parkaging Spirification From: Geller, Shelby CTR (PHMSA) 15-0074 Sent: Monday, April 13, 2015 1:55 PM To: Hazmat Interps Subject: FW: Formal Interpretation Request Attachments: 4B liner interp.pdf Good Afternoon Shante and Alice, Attached is a formal letter of interpretation. Please let me know if you need anything else. Thanks, Shelby Geller Sent: Monday, April 13, 2015 10:29 AM' From: Sherrier, Jason (Fairfield) [mailto:Jason.Sherrier@sgs.com] To: INFOCNTR (PHMSA) Subject: Formal Interpretation Request Good Morning, Please find my attached formal interpretation request and advise if anything else is needed. Thank you in advance. Jason Sherrier Consumer Testing Services Lab Manager, Packaging & Building Materials 291 Fairfield Ave SGS - North America Fairfield, NJ 07004 Main: Mobile: +1 973-294-1412 Fax: +1 973-575-7175 -1 973-461-7918 E-mail: :jason.sherrier@sgs.com www.sqs.com Information in this email and any attachments is confidential and intended solely for the use of the individual(s) to whom it is addressed or otherwise directed. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the Company. Finally, the recipient should check this email and any attachments for the presence of viruses. The Company accepts no liability for any damage caused by any virus transmitted by this email. All SGS services are rendered in accordance with the 1#

Page 4SGS U.S. Department of Transportation East Building, PHH-32 Pipeline & Hazardous Materials Safety Administration April 13' , 2015 Washington, DC 20490-001 1200 New Jersey Avenue, SE Attn: Info Center liner is necessary for all metal boxes with reference to Rule 52 FR 67403. The purpose of this letter is to request a formal interpretation of §178.512(b)(2) of the 49 CFR to determine if a (with gaskets) that is intended to transport a solid PG III, filter material. The intended PG III material is non The container in question is a five sided canister type 4B aluminum box with a removable top and bottom plates end use of this product. No welds are present on this design so ingress of the material into any seam in not explosive and a liner and or coating on the inside of the container described in §178.512(b)(2) interferes with the stacking. possible. The box was tested to a PG Ill and performed very well against the requirements for drop, vibration and When an informal question was asked to Transportation Specialist Michael Nicks, he directed me to Rule 52 FR formal interpretation. 67403 which references "unlined and lined" aluminum boxes are identified as 4B however suggested I request a To simplify my question, Can we certify this 4B aluminum box without a liner being present? Thank you in advance. SIGNED FOR AND ON BEHALF OF SGS North America, Inc. 08 Jason Sherrier CA2006080033 (+BA) Laboratory Manager SGS North America, inc.. Consumer Testing Services 291 Fairfield Avenue, Fairfield, NJ 07004 t (973) 575-5252 1(973) 575-8271 www.sgs.com/ Member of the SGS Group (Societe Génerale de Surveilance"#

Page 5applicable SGS conditions of service available on request and accessible at http://www.sgs.com/en/Terms- and-Conditions.aspx 2#