Mitsubishi Motor Manufacturing of America — Hazardous Materials Safety Interpretation

Page 1... 173-166 U.S. Department of Transportation Washington, D.C. 400 Seventh Street, S.W 20590 Special Programs Research and Administration JUN 2 1999 Mr. Edwin C. Amsler Ref. No. 98-0374 Mitsubishi Motor Manufacturing of America 100 N. Mitsubishi Motorway Normal, IL 61761 Dear Mr. Amsler: This is in response to your letter dated October 29, 1998, concerning air bag devices that are packed in non-specification, reusable high strength plastic containërs for transportation from a manufacturing facility to the assembly facility under § 173.166 (e) (4) Parts 171-180). of the Hazardous Materials Regulations 149 CFR You state that the airbag devices are packed in open-top reusable have lids and are constructed to interlock when stacked on top of containers that are stacked on a skid. The containers do not stacked containers are then banded twice in both directions to each other, with a top cap placed on the topmost container. The loading configurations for the air bags as prepared for the skid. You enclosed four photographs showing two different transportation. Your questions are paraphrased and answered as follows: Q1. Do the containers depicted in attachments 1 and 1-A meet the requirements prescribed in § 173.166 (e) (4) (ii) ? A1. section 173.166 (e) (4) (ii) requires a container or dedicated handling device that is not completely enclosed by design to be covered with plastic, fiberboard, or metal and secured to the container by banding or other comparable methods. the opinion of this Office that your stacked, high strength plastic containers when fitted with a top cap and securely banded to the skid satisfy the requirements of a dedicated handling device. 02. Do the closures on the containers depicted in attachments 2 and 2A meet the requirements prescribed in § 173.24 (f) ? 980374#

Page 2..i.0 A2. The general requirements in § 173.24 apply to all packagings. As required by § 173.24 (f), the closure on a container must be designed, closed and secured to the container so that under conditions (including the effects of temperature and vibration) normally encountered in transportation there is no release of the hazardous material from the container. Therefore, your packaging configurations would satisfy the applicable requirements provided the following conditions are met: (1) the air bag devices are properly secured against movement within the containers ($ 173.166 (e) (4) (iii)); and (2) the skid of stacked containers fitted with a top cap is tightly secured to prevent both the release of the airbag devices from the containers and the release of the containers from the skid during normal transportation conditions. Please contact this office if we can be of further assistance. copy of this response has been sent to the Illinois Department of Transportation, Division of Traffic Safety. Sincerely, Hottie z. Mitchell Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3MITSUBISHI MOTOR MANUFACTURING OF AMERICA, InC Mr. E. T. Mazzullo Director, Office of Hazardous Materials U. S. Department of Transportation, RSPA 400 - 7* Street, South West Washington D.C., 20590-0001 Date: October, 29, 1998 Subject: Clarification of 49CFR, 178.166(e)(4)(ii) 49CFR, 173.24(f) Dear Mr. Mazzullo, I would like to get a clarification and interpretation of the above packaging standards. I have attached pictures (with descriptions of the packaging) of two different styles of packaging. .i. S: Please advise if these meet the guidelines of the 49CFR. If in your opinion and interpretation, they do not meet the guidelines, what must be changed to meet your interpretations of the standards. Thank you for your assistance in this matter, Sincerely, EdiP. lemeles Edwin C. Amsler Operations Specialist/Safety Coordinator Attach: Pictures with explanations of packaging (Attach: 1 and 1A) (Attach: 2 and 2A) 100 N. MITSUBISHI MOTORWAY NORMAL, IL 61761 (309) 888-8000#

Page 4Does this meet the requirements of 49CFR 178.166(e)(4)(ii)? Please note that each container does not have a lid. We place the containers on top of each other and then put a top cap on the skid. It is then banded twice in both directions. 21. 1: Attachment #1#

Page 5NOTE: Containers do not have individual lids. Containers are stacked on top NE of each other to form a covering. Top cap is placed on top and banded twice in both directions#

Page 6NOTE: Ties are not inserted into lids. Does this package meet the guidelines of the 49 CFR 173.24(f)? AttAchment# 2#

Page 7NOTE: Lids are not tied down with tie downs Attachment # 2-A#