Lockheed Martin — Hazardous Materials Safety Interpretation

Page 1Christian Calvo Lockheed Martin 1011 Lockheed Way MailDrop 6601 Palmdale, CA 93599 Reference No. 17-0108 Dear Mr. Calvo: This letter is in response to your September 27, 2017, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the reuse of a non-bulk combination packaging. You state that a vendor ships a Class 8 (corrosive) material in a combination packaging that consists of a sealed metal tank (inner packaging) and a 4H2 plastic box (outer packaging), to another location. You also state that once the packaging arrives, the inner packaging is removed and replaced by an unserviceable metal tank of the same design for shipment back to the vendor. Specifically, you ask whether the return of the combination packaging would be limited to one reuse without retesting or reconditioning per § 173.12(c)(5). The answer is no. Since the shipment does not contain a hazardous waste, the provisions of § 173.12 do not apply. Provided the packaging does not show evidence of a reduction in integrity, one may continue to reuse the packaging. Please see § 173.28 for the conditions and limitations for reuse of packagings. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Not The Pite Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Please submit this as a letter of interpretation. Let me know if you have any questions. Thanks, Jodi From: Calvo, Christian D [mailto:christian.d.calvo@lmco.com] Sent: Thursday, September 28, 2017 5:18 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: RE: Request for Clarification - Hazardous Material Regulation (49 CFR Parts 171-180) Hello, This email is in response to a voice message I received on 9/28/2017 requesting to add a phone number to my request for clarification, below. My phone number is: (661) 572-7556 Thank you, Christian Calvo Lockheed Martin Aeronautics Company 1011 Lockheed Way MailDrop 6601 Palmdale, CA 93599 christian.d.calvo@lmco.com (661) 572-7556 From: Calvo, Christian D (US) Sent: Wednesday, September 27, 2017 2:54 PM To: 'infocntr@dot.gov' <infocntr@dot.gov> Subject: Request for Clarification - Hazardous Material Regulation (49 CFR Parts 171-180) Hello, I am requesting written clarification on 49 CFR Part 173.12(c) Reuse of packagings. Currently I am looking into the requirements for shipping a Class 8, Packaging Group I! liquid in a non-bulk combination packaging consisting of a sealed metal tank (inner packaging) to hold the liquid and a 4H2 plastic box (outer packaging) per §173.202. Both the inner and outer packagings are designed specifically for this product. Operationally, a packaging is transported from the vendor to another location where the inner tank is removed from the outer packaging for use. An unserviceable tank that may still contain the hazardous liquid is then placed inside the#

Page 3Christian Calvo Lockheed Martin Aeronautics Company 1011 Lockheed Way MailDrop 6601 Palmdale, CA 93599 christian.d.calvo@lmco.com#