{"operation":"document","citation":"17-0038","title":"RASIRC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-11-14","effective_on":null,"summary":"17-0038 response to RASIRC concerning 173.24.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0038.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0038.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0038","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56151/170038.pdf","body":"<<<PAGE 1>>>\n\nAnalytical Services Supervisor\nRASIRC\n7815 Silverton Avenue\nSan Diego, CA 92126\nReference No. 17-0038\nDear Mr. Woon:\nThis letter is in response to your April 12, 2017, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of hydrogen\nperoxide by air. You describe a scenario where \"UN3098, Oxidizing liquid, corrosive, n.o.s.\n(hydrogen peroxide), 5.1, II\" is being shipped in 250-750 mL containers that have a pressure\nrelief device installed to open when reaching an internal pressure of 0.5 psi. You further note\nthat § 173.24(g) only allows the venting of packagings when air transport is not involved.\nSpecifically, you ask if the container described in your letter can be placed in an outer packaging\n(i.e., heat sealable pressure bag, United Nations (UN) rated drum or pressure vessel) and be\nshipped by air while in compliance with § 173.24(g).\nThe answer is no. As you note, § 173.24(g) of the HMR does not allow for venting of\npackagings when air transport is involved, except for shipments of cryogenic liquids and dry ice.\nHowever, special permits may authorize relief from any requirement in the HMR, provided the\napplicant demonstrates an equivalent level of safety to that intended by the regulation. To apply,\nyou must submit an application to the Associate Administrator for Hazardous Materials Safety in\nconformance with the requirements prescribed in 49 CFR Part 107, Subpart B. You may obtain\ninformation on the special permit application process from our Web site at\nhttp://www.phmsa.dot.gov/hazmat/regs/sp-a, or by calling the Approvals and Permits Division at\n(202) 366-4511.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nPlease submit this as a letter of interpretation. Mr. Woon spoke with Jodi.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Ryan Woon [mailto:rwoon@rasirc.com]\nSent: Wednesday, April 12, 2017 1:10 PM\nTo: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>\nSubject: Interpretation Letter Request\nHello,\nI've submitted the attach letter with a question in regards to regulations stated in the Hazardous Material Regulations\nsection in 49CFR.\nThank you for your time and I look forward to hearing from you.\nRyan\nRyan Woon\nAnalytical Services Supervisor\nRASIRC\n7815 Silverton Ave.\nSan Diego CA 92126\n(858)-259-1220 ext. 253\n-- The information contained in this communication and any attachments is confidential and may be privileged,\nand is for the sole use of the intended recipients). Any unauthorized review, use, disclosure or distribution is\nprohibited. Unless explicitly stated otherwise in the body of this communication or the attachment thereto (if\ntwarantes or liabilies. To\nany, the information is provided on an AS-IS basis without any express or implied warranties or liabilities. To\nthe extent you are relying on this information, you are doing so at your own risk. If you are not the intended\nrecipient, please notify the sender immediately by replying to this message and destroy all copies of this\nmessage and any attachments. RASIRC is neither liable for the proper and complete transmission of the\ninformation contained in this communication, nor for any delay in its receipt.\n\n<<<PAGE 3>>>\n\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nEast Building, 2nd Floor\nWashington, DC 20590\nTo whom this may concern,\nMy e-mail is in regards to shipping non bulk packages under the regulations stated in the Hazardous\nMaterial Regulations section in 49CFR via air transport.\nThe chemical is UN 3098 PG II and the technical name is, \"Hydrogen Peroxide\". The chemical is stored in\na container that has a pressure relief valve installed on it that opens up when an internal pressure over\n0.5psi is observed. The shipping volume would vary between 250-750mL per container.\nUnder 173.24(g), venting of packages is only allowed when air transport is not involved. Can the inner\ncontainer be placed in intermediate packaging or an outer package in order to meet requirements? The\ngoal of the intermediate packaging or the outer package would be to prevent unintentional release of\nhazardous materials into the air transport.\nThe package design would place the inner container in intermediate packaging that is a heat sealable\npressure bag rated for 95kPA. This would then go into a 4GV packaging kit tested to carry the inner\ncontainer.\nIf not acceptable, another option is to place the inner container in an outer package such as a UN rated\ndrum that can hold 200kPA or a UN rated pressure vessel. The UN rated pressure vessels typically hold\nup to 115psi or more.\nIf you have any questions or need further clarification, please do not hesitate to contact me.\nThank you for your time and I look forward to hearing back from you.\nRyan\nRyan Woon\nAnalytical Services Supervisor\nRASIRC\n7815 Silverton Ave.\nSan Diego CA 92126\n(858)-259-1220 ext. 253","truncated":false,"body_characters":5073}