{"operation":"document","citation":"20-0018","title":"Mark B. Hawk — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-05-12","effective_on":null,"summary":"20-0018 concerning 173.412, 173.415, 173.465.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73901/200018.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 12, 2020\nMark B. Hawk\nPackaging Management Council Coordinator\n8116 Villa Grande Lane\nKnoxville, TN 37938\nReference No. 20-0018\nDear Mr. Hawk:\nThis letter is in response to your February 25, 2020, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Type A\npackaging free drop test requirements.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether the reference to “safety features” in § 173.465(c) is referring to the parts\nof the Type A packaging that meet the performance requirements in § 173.412(j).\nA1. The answer is yes. Section 173.465 details the requirements for Type A packaging tests,\nand to be considered successful, the packaging must meet the requirements of\n§ 173.412(j).\nQ2. You ask whether the requirement in § 173.412(j)(2) that the packaging prevent “a\nsignificant increase in radiation levels recorded or calculated at the external surfaces for\nthe condition before the test” means that a significant decrease in radiation levels at the\nsurface of the package does not need to be considered.\nA2. The answer is yes. Section 173.412(j)(2) requires that the packaging will prevent “a\nsignificant increase in radiation levels recorded or calculated at the external surfaces for\nthe condition before the test.” If after the free drop test in § 173.465(c) there is not a\nsignificant increase in radiation levels at the external surface of the package, the package\nis considered to have met the requirements in § 173.412(j)(2).\n\n<<<PAGE 2>>>\n\nQ3. You ask whether the requirement in § 173.412(j)(2) that the packaging prevent “a\nsignificant increase in radiation levels recorded or calculated at the external surfaces for\nthe condition before the test” means that a significant increase or decrease in radiation\nlevels at 1 meter from the surface of the package does not need to be considered as a\nperformance standard.\nA3. The answer is yes. See A2.\nQ4. You ask whether the safety features of the Type A packaging need to be clearly identified\nprior to performing the free drop test in § 173.465(c) and any damage to the packaging be\ndescribed on the test report after conducting the free drop test.\nA4. The answer is yes, if testing a DOT Specification 7A packaging subject to § 173.465.\nSection 173.415(a)(1)(i) requires documentation of testing for packagings subjected to\nthe physical tests of § 173.465, and if applicable, § 173.466. This documentation\nincludes a detailed description of each test performed and the damage to each item of the\ncontainment system resulting from the test. For other Type A packaging, see\n§§ 173.415(b)-(d) for their requirements.\nQ5. You ask how it is expected to determine the worst-case drop orientation for the Type A\npackaging to suffer maximum damage in § 173.465(c). You also ask if multiple drop\norientations might be needed.\nA5. As noted, § 173.465(c) requires that the Type A packaging be dropped onto the target so\nas to suffer maximum damage to the safety features. The Type A packaging and testing\nrequirements are performance oriented and this Office is not able to determine the most\nappropriate orientation method for any one specific packaging configuration. There is no\nrestriction to conducting multiple drop orientations to determine the worst-case drop\norientation in order to meet § 173.465(c).\nQ6. You ask when testing a Type A packaging containing fissile material, whether after\nperforming the § 173.465(c)(2) free drop test, the packaging needs to be evaluated for\nany damage and then determine the orientation for maximum damage prior to performing\nthe free drop test in § 173.465(c)(1).\n\n<<<PAGE 3>>>\n\nA6. As required in § 173.465(c)(2), for packages containing fissile material, the free drop test\nin § 173.465(c)(1) must be preceded by a free drop from a height of 0.3 m (1 ft.) on each\ncorner, or in the case of cylindrical packages, onto each of the quarters of each rim. After\nthis test is conducted, the free drop test in § 173.165(c)(1) must be performed and the\npackage must be dropped onto the target so as to suffer maximum damage to the safety\nfeatures.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 4>>>\n\nGeller\nJanuary, Ikeya CTR (PHMSA)\n20-0018\nFrom:\nINFOCNTR (PHMSA)\nSent:\nTo:\nWednesday, February 26, 2020 11:02 AM\nHazmat Interps\nSubject:\nFW: Request for Clarification\nAttachments:\nRequest for Clarification - Type A Testing 2-25-2020.pdf; Mark Hawk Letter.docx\nHello Alice and Ikeya,\nAttached is a request for Letter of Interpretation.\nThanks,\nJonathon, HMIC\nFrom: Mark Hawk [mailto:hawkn14@gmail.com]\nSent: Tuesday, February 25, 2020 9:40 AM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: Request for Clarification\nTo Whom It May Concern:\nAttached is a request for clarification concerning Free Drop Testing of Type A packages.\nIf you have any questions, please contact me.\nBest Regards,\nMark B. Hawk\nPackaging Management Council Coordinator\n8116 Villa Grande Lane\nKnoxville, TN 37938\nPhone: 865-250-3300\nE-mail: hawkn14@gmail.com\n1\n\n<<<PAGE 5>>>\n\nFebruary 25, 2020\nStandards and Rulemaking Division\nPipeline and Hazardous Materials Safety Administration (PHMSA)\nU.S. Department of Transportation (DOT)\n1200 New Jersey Avenue, SE\nWashington, CE 20590-0001\nSubject: Request for Clarification Concerning 49 CFR 173.465(c), Type A Packaging Free Drop Testing\nDear Sir/Madam:\nClarifications to the questions below are requested as to the method(s) allowed by the DOT/PHMSA for\nperforming free drop testing of Type A packages in accordance with 49 CFR 173.465(c) and a question as\nto the result of the tests as stipulated in 173.412(j)(2).\nQuestion 1:\nIs the correct understanding of the term \"safety features \"in 49 CFR 173.465(c), those components of a\npackaging that provide reasonable assurance they will perform their intended safety function and\nprevent loss or disposal of the radioactive content and prevent an increase in radiation levels at the\nexternal surface, as stipulated in 173.412(i)?\nQuestion 2:\n49 CFR 173.412(i) states \"When evaluated against the performance requirements...the packaging will\nprevent - (2) A significant increase in the radiation levels recorded or calculated at the external surface\nfor the condition before the test.\"\nIs the explicit reference to a significant \"increase\" in radiation levels \"at the external surface\" intended\nto imply that:\n...a significant decrease at the surface need not be considered as a performance standard?\n...a significant increase or decrease at 1 meter need not be considered as a performance\nstandard?\nEither of these conditions may imply a change in the internal shielding configuration or could mean that\na post-test (or en route or post-shipment) condition would require a different Transport Index or label.\nQuestion 3:\nPrior to performing testing described in 173.465(c)(1and (c)(2), must the safety features (173.465(c)) be\nclearly identified and the resulting test report describe the damage, if any, to the safety features?\nQuestion 4:\nPrior to performing testing described in 173.465(c)(1) and (c)(2), how does DOT/PHMSA expect the\ntester to determine the worst-case drop orientation to suffer maximum damage to the safety features\nbeing tested? In 49 CFR 173.465(c)(1) and (c)(2), it appears to only require one test specimen; however,\nit seems as though it could take multiple test specimens and multiple drop orientations to actually\nchallenge the safety features in question?\n\n<<<PAGE 6>>>\n\nQuestion 5:\nAfter performing the 1 foot free drop tests in 49 CFR 173.465(c)(2) and prior to performing the free drop\ntest in 49 CFR 173.465(c)(1), does the tester have to evaluate the damage from the 1 foot drop tests,\nand then determine the worst case drop orientation (angle of drop, point of impact, etc.) that will cause\nthe maximum damage to the safety features prior to performing the 49 CFR 173.465(c)(1) free drop\nYour clarification of these issues will be appreciated.\nRespectfully,\nMark B. Hawk\nPackaging Management Council Coordinator\n8116 Villa Grande Lane,\nKnoxville, TN 37938\nPhone: 865-250-3300","truncated":false,"body_characters":8378}