{"operation":"document","citation":"20-0053","title":"Hasa, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-04-27","effective_on":null,"summary":"20-0053 response to Hasa, Inc. concerning 173.28.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0053.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0053.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0053","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/74946/200053.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nApril 27, 2021\nMr. Dave Johnson\nHasa, Inc.\n23119 Drayton Street\nSaugus, CA 91350\nReference No. 20-0053\nThis letter is in response to your July 17, 2020, letter and subsequent emails requesting\nclarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable\nto pressure differential testing. In your letter, you state that your company reuses and refills 5,\n15, 30, and 55 gallon polyethylene drums—rated for Packing Group (PG) II or III materials—\nwith materials similar to materials the drums previously contained. You ask whether your\ncompany’s proposed test procedure, as outlined below, is in compliance with the pressure\ndifferential testing requirements specified in paragraph 2 of Appendix B to Part 178 - Alternative\nLeakproofness Test Methods.\nYou described your proposed test procedure as follows:\n• A test fixture with a single pressure gauge is connected to an opening in the drum. All\nother openings on the drum are sealed with closures.\n• Utilizing a compressed air source and hand valve, the drum under test is pressurized to\n3 psig, as indicated on a single pressure gauge measuring the internal pressure of the\ndrum.\n• A hand valve is closed, isolating the air source from the drum and pressure gauge\nmeasuring the internal pressure of the drum.\n• The pressure gauge is monitored for one minute. If no pressure drop is observed on the\npressure gauge, the drum is considered to pass the test and is marked accordingly, per\n§ 173.28. If the pressure is not maintained, the drum is considered to fail and is marked\nout of service and disposed of through a plastic recycler.\nIt is the opinion of this Office that the proposed test procedure you describe complies with the\npressure differential test requirements in paragraph (2) of Appendix B to Part 178. Therefore,\nthe PG II and III polyethylene drums that successfully pass this test may be reused and refilled\nunder § 173.28, provided these packagings comply with all applicable requirements of the HMR.\nPlease be advised that plastic drums may expand under pressure. Therefore, it is recommended\n\n<<<PAGE 2>>>\n\nthat the drums be pressurized to 20kPa and held at that pressure prior to testing. In addition, as it\nmay be difficult to detect a slow leak, it is also recommended that a low-pressure gauge be used.\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\n20-0053\nHB&B\n, Inc.\nShane Kelley\nDirector, Standards and Rulemaking Division\nUS DOT/PHMSA (PHH-10)\n1200 New Jersey Avenue, SE East Building, 2nd Floor\nWashington, DC 20590\nSubject: Letter of Interpretation concerning 49 CFR Part 178, Appendix B - Alternative Leakproofness\nTest Methods\nDear Mr. Kelley,\nHasa is requesting a letter of interpretation concerning the alternate leakproofness test methods\ncontained in 49 CFR Part 178, Appendix B. Specifically, Hasa is seeking a determination that our test\nmethod and procedure for reusing non-bulk plastic packages is compliant with the Pressure differential\ntest regulations contained in paragraph (2) of 49 CFR Part 178, Appendix B. See referenced paragraph\nbelow:\n(2) Pressure differential test. The packaging shall be restrained while either pressure or a\nvacuum is applied internally. The packaging must be pressurized to the pressure required by\n§178.604(e) of this subchapter for the appropriate packing group. The method of restraint must\nnot affect the results of the test. The test must be conducted for a period of time sufficient to\nappropriately pressurize or evacuate the interior of the packaging and to determine if there is\nleakage into or out of the packaging. A packaging passes the pressure differential test if there is\nno change in measured internal pressure.\nHasa is refilling plastic poly 5,15,30, and 55 gallon drums with the same type of products in accordance\nwith CFR § 173.28. All containers are being packaged in Packing Group II or III UN approved\ncontainers.\nHasa is specifically requesting if the following test procedure methodology is compliant with paragraph\n(2) of 49 CFR Part 178, Appendix B:\n• A test fixture with a single pressure gauge is connected to an opening in the drum. All other\ndrum openings are sealed with closures.\n• Utilizing a compressed air source and hand valve the drum under test is pressurized to 3 psig as\nindicated on a single pressure gauge measuring the internal pressure of the drum.\n• A hand valve is closed isolating the air source from the drum and pressure gauge measuring the\ninternal pressure of the drum.\nHasa, Inc. 23119 Drayton Street, Saugus, CA 91350 Phone: 661-259-5848 Fax: 661-259-1538\n\n<<<PAGE 4>>>\n\nPlease advise if the above leakproofness test methodology procedure complies with the current DOT\nregulatory requirements for conducting the pressure differential test under 49 CFR Part 178, Appendix\nB, paragraph (2) for the reuse and refilling of packages under 49 CFR 173.28.\nIf you need any further information or have any questions, please feel free to contact myself at (925)\n432-3866.\nSincerely,\nDish\nDave Johnson\nHasa Inc.\nHasa, Inc. 23119 Drayton Street, Saugus, CA 91350\nPhone: 661-259-5848\nFax: 661-259-1538","truncated":false,"body_characters":5424}