Interpretation Response #01-0208 ([MMA] [Mr. Winiam J. Schuchman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: MMA
Individual Name: Mr. Winiam J. Schuchman
Location State: MO Country: US
View the Interpretation Document
Response text:
October 11, 2001
Mr. Winiam J. Schuchman Reference No. 01-0208
Executive Director
MMA
10733 Big Bend Blvd.
St. Louis, MO 63122-6027
Dear Mr, Schuchman:
T'his is in response to your July 30, 2001 letter and subsequent conversations with Michael Johnsen of my staff concerning the determination of the packing group for a flammable liquid under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked for clarification of the criteria for inclusion of viscous Class 3 materials in Packing Group III provided in the table in § 173.121 (b)(1)(iv) for viscous materials with a flash point under 23 degrees C (73 degrees F).
Your example involves a viscous material that has a flow time of about 90 seconds through a 4 mm diameter jet and has a flash poit of 7O degrees F. To determine if a material could be considered a Packing Group III material, the conditions in § 173.121 (b)(1)(i) - (iv) must be met. Your question concerns interpreting the table in § 173.121(b)(1)(iv). You would first identify your flow time in column one through a jet diameter indicated in column two. Column three indicates the minimum flashpoint for your material to be considered a Packing Group III material. A material, with a flow time of 90 seconds through a 4 mm diameter jet, falls between the range in the second entry and requires a flash point above 10 degrees C (50 degrees F) to qualify for a Packing Group III material. Since the material in this example has a flash point of 70 degrees F, then it is considered a Packing Group III material if, in addition, the material also meets all other requirements of § 173.121 (b)(1).
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
173.121(b)
Regulation Sections
| Section | Subject |
|---|---|
| 173.121 | Class 3-Assignment of packing group |