{"operation":"document","citation":"22-0036","title":"Haz-Mat One — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2023-08-01","effective_on":null,"summary":"22-0036 response to Haz-Mat One concerning 173.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0036.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0036.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0036","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/77891/220036.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAugust 1, 2023\nMr. Travis Hillmer\nGeneral Manager\nHaz-Mat One\n1203 C South Parker Rd\nOlathe, KS 66061-4200\nReference No. 22-0036\nDear Mr. Hillmer:\nThis letter is in response to your April 29, 2022, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of salvage drums\nused to transport leaking packages containing Packing Group (PG) I (great degree of hazard)\nhazardous materials.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether PG I packages found to be leaking in transportation—containing PG I\nhazardous materials—may be placed in a PG III (minor degree of hazard) (“Z” rated)\nsalvage drum.\nA1. Packages of hazardous materials that are damaged, defective, or leaking; packages found\nto be not conforming to the requirements of the HMR after having been placed in\ntransportation; and hazardous materials that have spilled or leaked may be placed in a\nmetal or plastic removable head salvage drum that is compatible with the lading and\nshipped for repackaging or disposal under the conditions as specified in § 173.3(c). In\naccordance with § 173.3(c)(1), the drum must be a UN 1A2 (removable head steel drum),\n1B2 (removable head aluminum drum), 1N2 (removable head metal (other than steel or\naluminum) drum), or 1H2 (removable head plastic drum), tested and marked for PG III\n(minor degree of hazard) (“Z” rated) or higher (i.e., “X”, “Y”, or “Z” rated) performance\nstandards for liquids or solids and a leakproofness test of 20 kPa (3 psig).\nQ2. You ask whether a PG II (“Y” rated) or PG III (“Z” rated) salvage drum is authorized for\nthe transportation of PG I, PG II, or poisonous by inhalation (PIH) hazardous materials\npackages found to be leaking or damaged in transportation.\n\n<<<PAGE 2>>>\n\nA2. The answer is yes. See answer A1.\nQ3. You ask if a PG I package is placed in a salvage drum due to a leak or damage, whether\nthe salvage drum must be rated for PG I (“X” rated) or may it be tested and marked for\nPG II (“Y” rated) or PG III (“Z” rated).\nA3. See answer A1.\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\nPollack\nFrom: Raynor, T\"Mia (PHMSA)\nTo: Hazmat Interps\nSubject: FW: Interpretation Response Request\nDate: Friday, April 29, 2022 1:16:23 PM\nAttachments: Salvage Drum Interpretation Request.pdf\nimage003.png\n22-0036\nGood Afternoon,\nPlease see attached.\nThanks,\nT’Mia Raynor\nWebmaster, Office of the PHMSA CIO\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave. SE, Washington, D.C., 20590\nOffice: 202.366.9818 ◊ Mobile: 202.580.9447\nPHMSA Home | LinkedIn | Twitter | HAZMAT | OPS\nFrom: Travis J. Hillmer <thillmer@haz-matresponse.com>\nSent: Friday, April 29, 2022 1:09 PM\nTo: PHMSA Website Manager <PHMSAWebsiteManager@dot.gov>\nSubject: Interpretation Response Request\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nAttached is an interpretation response request pertaining to Salvage Drum requirements for\ndamaged PGI, PGII, and PIH shipments.\nThank you for your consideration,\nTravis J. Hillmer Haz-Mat One General Manager 800-229-5252 ext. 257\nthillmer@haz-matresponse.com\n\n<<<PAGE 4>>>\n\nHAZ-MAT ONE®\n\"Your First Line of Defense\"\n\n<<<PAGE 5>>>\n\nHAZ-MAT ONE®\n[Haz-Mat Response, Inc. sm]\nTo whom it may concern,\nI am writing to request an interpretation of the 49 CFR regulations as they pertain to the requirements for salvage drums\nfor damaged/leaking shipments of PGI, PGII and/or PIH hazardous materials.\nHMR; 49 CFR Part 173.3(c)(1):\nExcept as provided in paragraph (C) (7) of this section, the drum must be a UN 1A2, 1B2, 1N2 or 1H2 tested and\nmarked for Packing Group III or higher performance standards for liquids or solids and a leakproofness test of\n20 kPa (3 psig). Alternatively, a drum manufactured and marked prior to October 1, 1993 as a salvage drum, in\naccordance with the provisions of this section in effect on September 30, 1991, is authorized. Capacity of the\ndrum may not exceed 450 L (119 gallons).\nThree questions:\nDo the regulations state that the salvage drum utilized need only meet the listed specifications and are not requiring the\noverpack to meet the specifications or bear the marking of an X rated salvage drum, tested and marked for Packing\nGroup I performance standards for liquids or solids?\nWould a Y and/or Z rated salvage drum, as long as the rest of the requirements of the paragraph are met, be an\nacceptable salvage drum for damaged/leaking PGI, PGII, and PIH shipments?\nIs a salvage drum for a damaged PGI shipment required to carry an X rating, or are Y and Z rated drums sufficient\nas long as the other requirements in 173.3 are met?\nSincerely,\nTravis Hillmer\nGeneral Manager\nHaz-Mat One","truncated":false,"body_characters":5173}