USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #11-0206 ([CH2MHill] [Mr. Chris Backus])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: CH2MHill

Individual Name: Mr. Chris Backus

Location State: WA Country: US

View the Interpretation Document

Response text:

September 20, 2011

 

 

Mr. Chris Backus

Packaging Engineer

CH2MHill

P.O. Box 1600 MSIN T3-11

Richland, WA 99354

Reference No.: 11-0206

Dear Mr. Backus:

This responds to your August 26, 2011 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to tie-down attachment requirements for Type A packages in accordance with § 173.412(i). Your questions are paraphrased and answered as follows:

Q1. Are accident conditions for Type B packages contained in 10 CFR § 71.45 applicable to Type A packages?

A1. The answer to your question is no. The static force requirements in 10 CFR § 71.45 are prescribed for packages designed for the transport of radioactive materials indicated in 10 CFR § 71.0.



Q2. Are there load cases indicative of "accident conditions" for Type A packages?

A2. There are no specific static force requirements that structural component tie-down attachments of Type A packages must be capable of withstanding referenced in the HMR. A packaging tie-down system should be designed so that it fails first in the event of an accident and the failure should not result in a tear or hole in the package containment or a reduction in shielding. Section 173.412(i) requires that in the event of an accident a failure of the tie-down system must not impair the ability of the package to meet the other requirements of Subpart I in the same manner as a failure during normal transportation conditions.



I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Delmer Billings

Senior Regulations Advisor

Standards and Rulemaking Division

173.412

Regulation Sections

Section Subject
173.412 Additional design requirements for Type A packages