{"operation":"document","citation":"16-0031","title":"Container Technologies Industries, LLC. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-08-18","effective_on":null,"summary":"16-0031 response to Container Technologies Industries, LLC. concerning 173.465.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0031.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0031.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0031","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/160031.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\nAUG 1 8 2016\nMr. Steve Fielden\nPresident/COO\nContainer Technologies Industries, LLC\n375 Marcum Parkway\nKelenwood, TN 37755\nReference No. 16-0031\nDear Mr. Fielden:\nThis responds to your February 19, 2016 e-mail requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180), the International Atomic Energy\nAgency (IAEA) Regulations for the Safe Transport of Radioactive Material TS-R-1, and\nassociated IAEA advisory material TS-G1.1. Specifically, you ask several questions\nconcerning the target for free drop tests on Type A packages. Your questions are\nparaphrased and answered below:\nQ1. You state that the IAEA advisory material TS-G1.1 provides more detailed guidance on\ntarget construction than currently found in § 173.465(c)(5) and in the TS-R-1. Given the\nguidance in TS-G1.1 you ask if it would be unacceptable to have a target constructed by\nsimply placing a loose steel plate over a paved or gravel surface with unknown soil\ncompaction and unknown soil density as flexure and deformation of the target in the vertical\ndirection would not be in conformance with the requirements of an unyielding surface.\nAl. The IAEA advisory material TS-G1.1 is not a document currently incorporated by\nreference into the 49 CFR. The HMR does not specifically authorize or prohibit particular\nmethods of preparing or assembling the target for Type A package drop tests, but rather\nprovides criteria that must be met. Section 173.465(c)(5) requires a target to be a flat\nhorizontal surface of such mass and rigidity that any increase in its resistance to displacement\nor deformation upon impact by the specimen would not significantly increase the damage to\nthe specimen. It is the opinion of this Office that this target configuration may be acceptable\nin some cases, such as for packages with a small gross mass, but unacceptable for packages\nwith a larger gross mass. The requirement in § 173.465 (c)(5) is that the target be of such\nmass and rigidity that increasing its resistance to displacement or deformation upon impact\n\n<<<PAGE 2>>>\n\n2\nby the specimen would not significantly increase the damage to the specimen. Said another\nway, the target must be of sufficient mass and rigidity that if you were to change the physical\nproperties of the target by adding more mass to or increasing the rigidity of the target there\nwould not be a significant increase in the damage to the specimen.\nQ2. You quote guidance from the IAEA advisory material TS-G1.1 that states \"the combined\nmass of steel and concrete should be at least 10 times that of the specimen to be dropped on\nit.\" You ask if given this guidance, a free drop test target constructed using a steel plate\nanchored and embedded in a thick concrete slab with a reaction mass greater than 10 times\nthe mass of the specimen to be tested can be considered in compliance with the requirements\nof an unyielding surface. Specifically, you ask if a 1 inch steel plate anchored to a thick\nconcrete slab with a total reaction mass of 350,000 Ibs can be considered a suitable target for\ndrop test specimens up to 35,000 Ibs.\nA2. As stated in Al above, § 173.465(c)(5) requires a target to be a flat horizontal surface of\nsuch mass and rigidity that any increase in its resistance to displacement or deformation upon\nimpact by the specimen would not significantly increase the damage to the specimen. It is\nimpossible for this Office to determine that the target mentioned in Q2 would be compliant in\nall possible testing scenarios. If the properties of the specimen being tested (e.g. material of\nconstruction, design configuration, etc) are such, that when utilizing the specific target\nmentioned in Q2, that a change in the physical properties of the target by adding more mass\nto or increasing the rigidity of the target would result in a significant increase in the damage\nto the specimen then that target would not be compliant with the requirements in\n§ 173.465 (c)(5).\nI hope this information is helpful. Please feel free to contact this Office if we can be of\nfurther assistance.\nSincerely,\nShove CHalley for\nDuane A. Pfund\nInternational Standards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\n•\nWebb\nSi thing tut\nGoodall, Shante CTR (PHMSA)\nFrom:\nGeller, Shelby CTR (PHMSA)\n16-0031\nSent:\nMonday, February 22, 2016 9:26 AM\nTo:\nHazmat Interps\nSubject:\nFW: Request for Clarification Type A Drop Test Requirement\nAttachments:\nDOT Drop Test Letter.pdf\nDear Shante and Alice,\nForwarded is a request for a formal letter of interpretation. I spoke with Mr. Fielden.\nThanks,\nShelby\nFrom: sfielden@ctifab.com [mailto:sfielden@ctifab.com]\nTo: INFOCNTR (PHMSA)\nSent: Friday, February 19, 2016 4:04 PM\nSubject: Request for Clarification Type A Drop Test Requirement\nDear Sir/Madam,\nPlease see attached letter requesting clarification of requirements for the target for a free drop test.\nYou may contact me for any questions using the information below.\nThank you,\nSteve\nSteve Fielden\nPresident/COO\nContainer Technologies Ind., LLC\n375 Marcum Pkwy.\nHelenwood, Tn. 37755\n423-569-2800 × 35\n(M) 865-603-2685\n\n<<<PAGE 4>>>\n\n2/19/2016\nOffice of Hazardous Materials Standards,\nPipeline and Hazardous materials Safety Administration\nAttn: PHH-10\nU.S. Department of Transportation\nEast building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nSubject: Clarification of Type A Drop Test Requirements (Target for a free drop test)\nDear Sir/Madam:\nAs you are aware, demonstration of compliance for the free drop test specified in Pipeline and\nHazardous Materials Safety Administration (PHMSA) DOT Regulation 49 CFR 173.465 (c) requires that\nthe Target be a rigid and non-yielding surface. Specifically, 49 CFR 173.465 (c) 5 states the following:\n(5)\nThe target for a free drop test must be a flat, horizontal surface of such mass and rigidity that\nany increase in its resistance to displacement or deformation upon impact by the specimen\nwould not significantly increase the damage to the specimen\"\nUnfortunately, the lack of further guidance from PHMSA with respect to the design and construction of\nthe target leaves some question as to the correct application of this requirement. For this reason, we\nare seeking PHMSA concurrence with our understanding of the basis for design and construction of the\nfree drop test target as outlined herein:\n1. In recognition of the alignment between PHMSA Hazardous Materials Regulations (HMR's) and\nInternational Atomic Energy Agency (IAEA) regulations, the guidance provided in IAEA\nregulations [Ref. 5, TS-R- (ST-1)] and [Ref.8, TS-G-1.1 (ST-2)] can be taken as a more detailed\nbasis for design and construction of the free drop test target. The applicable provisions from\nIAEA regulations are as follows.\n717.1\nThe target for a drop test is specified as an essentially unyielding surface. This\nunyielding surface is intended to cause damage to the package which would be\nequivalent to or greater than that anticipated for impacts onto actual surfaces\nor structures which might occur during transport. The specified target also\nprovides a method for assuring that analyses and tests can be compared and\naccurately repeated if necessary. The unyielding target, even though described\nin general terms, can be repeatedly constructed to provide a relatively large\nmass and stiffness with respect to the package being tested. So-called real\ntargets, such as soil, soft rock and some concrete structures, are less stiff and\ncould cause less damage to a package for a given impact velocity. In addition, it\nis more difficult to construct yielding surfaces that give reproducible test results,\nand the shape of the object being dropped can affect the yielding character of\n\n<<<PAGE 5>>>\n\nthe surface. Thus, if yielding targets were used, the uncertainty of the test\nresults would increase and the comparison between calculations and tests would\nbe much more difficult.\n717.2\nThe combined mass of steel and concrete should be at least 10 times that of the\nspecimen to be dropped on it.\n2. Given the guidance from IAEA regulations, it is unacceptable to have a target constructed by\nsimply placing a loose steel plate over a paved or gravel surface with unknown soil compaction\nand unknown soil density as flexure and deformation of the target in the vertical direction\nwould not be in conformance with the requirements of an unyielding surface.\n3. Given the guidance from IAEA regulations, a free drop test target constructed using a steel plate\nanchored and embedded in a thick concrete slab with a reaction mass greater than 10 times the\nmass of the specimen to be tested can be considered in compliance with the requirements of an\nunyielding surface. More specifically, a 1\" Steel plate anchored to a thick concrete slab with\ntotal reaction mass of 350,000 Ibs can be considered a suitable target for drop test specimens\nup to 35,000 Ibs.\nThank you in advance for your prompt consideration of this request. If additional information is needed,\nplease see contact information below.\nSincerely,\nStive\nFuelen\nSteve Fielden\nPresident/COO\nContainer Technologies Industries, LLC\n375 Marcum Parkway\nHelenwood, Tn. 37755\nPH: 426-569-2800 X 35\nsfielden@ctifab.com","truncated":false,"body_characters":9324}