Interpretation Response #03-0163 ([Defense Logistics Agency] [Ms. Janet Cravener])

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

Interpretation Response Details

Response Publish Date: 07/18/2003

Company Name: Defense Logistics Agency

Individual Name: Ms. Janet Cravener

Location State: PA Country: US

View the Interpretation Document

Response text:

Jul 18, 2003

Ms. Janet  Cravener               Reference No. 03-0163
Chief, Distribution Operations
Defense Logistics Agency
2001 Mission  Drive
New Cumberland, PA. 17070-5000

Dear Ms.  Cravener:

This responds to your June 26, 2003 letter and subsequent conversation with Mr. Darral Relerford concerning the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for performance-oriented packagings.  Specifically, you ask about the appropriate packaging for a shipment by air of ethylene oxide and propylene oxide mixtures, with not more than 30 percent ethylene oxide, Class 3, UN 2983, PG L

You propose to package your material in a combination package that consists of 5-liter plastic bottles contained within a 1A2 steel drum with a 4-mil polyethylene liner.  You note that the inner packaging does not meet the hydrostatic pressure requirements for air shipment, as required by § 173.27(c)(ii) of the HMR.

For transportation by aircraft, the outer packaging of a combination packaging containing inner packages of a PG I liquid product is not required to meet the 250 kPa (36 psig) test pressure prescribed in § 173.27(c)(3)(ii). Section 173.27(c)(3)(ii) only applies to single and composite packages intended to contain liquids.  Combination packages are not subject to the hydrostatic pressure test and marking requirements of §§ 178.605 and 178.503(a)(5) respectively.  Section 173.27(c)(2) requires that packages for which retention of liquid is a basic function must be capable of withstanding without leakage an internal pressure based on the vapor pressure of the material to be transported.  Section 173.27(c)(3)(i) allows inner packages that are not capable of meeting the pressure requirement to be placed in a supplemental packaging that meets the pressure requirements.  Note that, although § 171.8 of the HMR includes separate definitions for "inner packaging" and "inner receptacle" the terms are used interchangeably throughout the HMR and are not interpreted to be different items.

I hope this information is helpful.  Please contact us if you require additional assistance

Sincerely,

Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.27

Regulation Sections