{"operation":"document","citation":"18-0006","title":"Crown Packaging Technology, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-06-29","effective_on":null,"summary":"18-0006 response to Crown Packaging Technology, Inc. concerning 173.33, 178.33.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/58651/180006.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n1200 New Jersey Avenue, SE\nof Transportation\nWashington, DC 20590\nPipeline and Hazardous\nMaterials Safety\nJUN 2 9 2018\nAdministration\nMr. Jaime Suarez\nAdvisory Engineer\nCrown Technology\nCrown Packaging Technology, Inc.\n11535 South Central Avenue\nAlsip, IL 60803-3418\nReference No. 18-0006\nDear Mr. Suarez:\nThis letter is in response to your January 5, 2018, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the buckle ranges for a\nDepartment of Transportation (DOT) DOT 2P1. Specifically, you ask for confirmation of the\nbuckle/burst pressure requirements of the DOT 2P1 aerosol container.\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule on\nJanuary 21, 2016 under Docket No. PHMSA-2013-0042 (HM-233F) requiring all standards for a\nDOT 2P1 to remain the same as those for a DOT 2P, except the DOT 2P1 must also comply with\nthe variations prescribed in § 173.33c-2. For a DOT 2P1 to comply with § 178.33c-2, Variation\n1, one container out of each lot of 25,000 containers or less, successively produced per day,\ncomplete with ends assembled (and without a pressure relief system assembled) must be pressure\ntested to destruction at gauge pressure and must not burst below 240 psig. The lot must be\nrejected if containers with a pressure relief system described in § 178.33c-2(a) and assembled\nshow failure at a location other than the pressure relief system. For those containers with an end\nexpansion device, the lot must also be rejected if the container bursts prior to buckling of the\ndevice.\nYou note how the buckle ranges for DOT 2P1 in § 178.33c-2 differ from those prescribed in\nDOT Special Permit (SP) 7951. DOT-SP 7951 specifies that one out of each case lot of 10,000\ncylinders or less that comply with this special permit must be pressure tested to destruction. The\nentire lot must be rejected if failure occurs at pressure below 175 psig and over 210 psig, or\nfailure occurs at other than the rim-venting release device or dome expansion device.\nPHMSA chose to adopt the modified DOT 2P container design prescribed in DOT-SP 13601,\nwhich complies with the DOT 2P container and variations prescribed in § 178,,33c-2, as the new\nDOT 2P1 design. In the HM-233F final rule, PHMSA states the reasons for this are:\n\n<<<PAGE 2>>>\n\n• PHMSA found DOT-SPs 7951, 13601, and 14503, which authorized modified\npecific information on the relationship between each aerosol's functional range an\nnanufacturing and testing requirements for packagings similar to DOT 2P, lacke\ntested burst pressure.\n• PHMSA found DOT-SPs 7951 and 14503 established a standard for content pressure for\nwhich there was no HMR equivalent.\n• The relief system functioning ranges in these packagings have a higher upper bound and\nno minimum burst pressure other than those prescribed for a DOT 2P.\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 3>>>\n\nEdmonson\n§ 178.33c-2\nA erosal:\nDodd, Alice (PHMSA)\n18-0006\nFrom:\nINFOCNTR (PHMSA)\nSent:\nTo:\nThursday, January 11, 2018 3:40 PM\nHazmat Interps\nSubject:\nFW: Clarification of Aerosol DOT 2P1 Buckle/Burst Requirements\nHello All,\nThis is an interp request from Jaime Suarez. I reached out to him last week to get some clarifying answers and he spoke\nto someone today in the INFOCNTR. We directed him to 178.33c-2 and HM-233F for his question. He would still like to\nhave written guidance on his mentioned cylinders.\nRegards,\n-Breanna\nFrom: Suarez, Jaime [mailto:Jaime.Suarez@crowncork.com]\nSent: Friday, January 05, 2018 5:12 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nCc: McFadden, Douglas < douglas.mcfadden@crowncork.com>\nSubject: RE: Clarification of Aerosol DOT 2P1 Buckle/Burst Requirements\nI am following up on a call I had earlier with the PHMSA-Hazardous Materials information line. DOT 2P1 rating was the\nconsolidation of food stuff SPs (specifically SP 7951), in which specific buckle ranges were included as a requirement. In\nreviewing the DOT 2P1, there no longer appears to be specific ranges, and DOT 2P1 appears to follow the same\nbuckle/burst requirements as DOT 2P. The information line confirmed that there are no different buckle/burst\nrequirements included in the CFR.\nI would like to request a written interpretation letter to confirm the buckle/burst requirements of the DOT 2P1\nrating. Please let me know if further information is required to process my request.\nRegards,\nJaime Suarez\nAdvisory Engineer | CROWN Technology\nCrown Packaging Technology Inc., 11535 S. Central Avenue, 60803-3418, Alsip, IL | United States\nT: +1 708 239 5328 | www.crowncork.com\nCONFIDENTIALITY NOTICE\nThe information contained in this e-mail is intended only for the confidential use of the above named recipient. If you\nare not the intended recipient or person responsible for delivering it to the intended recipient, you have received this\ncommunication in error and must not distribute or copy it. Please accept the sender's apologies, notify the sender\nimmediately by return e-mail and delete this communication. Thank you.\n1","truncated":false,"body_characters":5251}