{"operation":"document","citation":"99-0270","title":"Sperry-Sun Drilling Services — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-03-15","effective_on":null,"summary":"99-0270 response to Sperry-Sun Drilling Services concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0270.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0270.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0270","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990270.pdf","body":"<<<PAGE 1>>>\n\n•\n•\nS. Departmer\nTransportatic\n400 Seventh Street, S.W\nWashington, D.C.\n20590\nResearch and\nAdministration\nSpecial Programs\nMAR 1 5 2000\nMr. Jack E. Gilbert, Jr.\nRef. No. 99-0270\nSperry-Sun Drilling Services\n4607 Highway 90 East\nBroussard, LA 70518\nDear Mr. Gilbert:\nThis is in response to your letter dated September 21,1999, requesting clarification on the packaging\nrequirements for gas samples under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\n180). Specifically, you ask whether shipping gas samples in bags placed in an open top can such as a\ncoffee can or paint can with a friction lid sealed with plastic-ring seals is permissible under the HMR.\nSection 173.306(a)(4)(iii) requires that non-pressurized gases, flammable be packed in hermetically\nsealed glass or metal inner packagings of not more than 2.5 L (0.5 gallons) overpacked in a strong\nouter packaging. You have proposed to place the gas sample in a plastic bag which is enclosed in a\none gallon round metal can closed with a friction lid and a HAZLOC ring lock.\nYou have provided no information to show that your proposed packaging meets the definition of\nhermetically sealed in § 171.8. If you determine that a 2.5 L (0.5 gallon) metal can closed with a\nfriction lid and a HAZLOC ring lock meets the definition of hermetically sealed, it can be used as an\ninner packaging as specified in § 173.306 (a)(4)(iii). The use of a one gallon metal can will require an\nexemption from the HMR. Exemption application procedures and requirements are provided in\n§ 107.105 of the HMR.\nI hope this answers your inquiry.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n173,22\n990270\n\n<<<PAGE 2>>>\n\nBoothe\nSeptember 21,1999\n§ |73.22\nJack Gilbert\nSperry-Sun Drilling Services\n99-0270\n4607 Hwy 90 East\n(318) 837-7574\nBroussard, LA 70518\nEdward Mazzullo\nUS DOT- RSPA (DHM-10)\nDirector, Office of Hazardous Materials\n400 7TH Steet, SW\nWashington, DC - 20590\nSubject: Hermetically Sealed Containers\nDear Sir:\npumped into 1-liter sample bags, are taken from the mud-pit area on offshore and land-based drilling rig:\nhave questions regarding the proper transportation of flammable gas samples. The samples, which will b\nand contain various hydrocarbons associated with oil/gas well drilling. They will then be shipped to the\ncustomer for analysis. The sample bags are multi-layered with the center layer being aluminum.\nOn June 3,1999, I spoke with David Moore, Hazardous Materials Information Office, about shipping\ncontainers meeting DOT's definition of hermectically sealed. In question was the double friction seal can\nbeing hermetically sealed. He also stated that to obtain a hermetically sealed container, one would have to\n(i.e. paint can) with a plastic locking ring. Mr. Moore stated that this would not meet the requirements of\nweld, braze, crimp, or use a gasketed lid. It was also his determination that the gas sample bags, which are\nmetal inner container.\nmulti-layered and sealed by utilizing a steel air valve that is capped, would not meet the requirements of the\nand crimping the lids on with a sealing machine.\nSince our conversation, Sperry-sun has purchased and has been using the open top cans (coffee can style )\nRecently, we had a meeting with one of our customers who wants us to use the friction lid type cans with\nplastic-ring seals. They believe that the IATA standards allows for the use of such cans and I have attached\nthe documentation that they have given me.\nPlease review the attachments and provide us with a determination in writing as the proper packaging\nThank you for your assistance,\nHall Delhe\nJack E. Gilbert, Jr.\nHSE Advisor","truncated":false,"body_characters":3696}